Privacy Policy

Version: 1.0  |  Last Updated: 29 October 2026

This Privacy Policy applies to all services offered by Holspin through the website holspin-australia.com (the "Platform"). By accessing or using the Platform, you confirm that you have read, understood, and agreed to the practices described in this document. If you do not agree, please discontinue use of the Platform immediately.

1. Introduction

Holspin is committed to protecting the personal information of every person who visits or registers on the Platform. We recognise that privacy is a fundamental right, and we have designed our data-handling practices to be transparent, proportionate, and consistent with applicable data-protection standards, including those reflected in the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Policy explains what personal data we collect, why we collect it, how we use and share it, and what rights you have in relation to that data. It should be read alongside our Terms and Conditions and our Responsible Gaming Policy, which form part of the overall agreement between you and Holspin.

If you have any questions about this Policy or our data practices, please contact us using the details set out in Section 13 below.

2. Data We Collect

We collect personal information only to the extent necessary to provide our services, comply with legal obligations, and maintain platform security. The categories of data we collect include:

2.1. Registration and Identity Data

• Full name and date of birth
• Residential address and country of residence
• Email address and telephone number
• Username and encrypted account password
• Copies of government-issued identity documents (e.g., passport, driver's licence) collected during Know Your Customer (KYC) verification

2.2. Financial and Transaction Data

• Payment method details (e.g., partial card number, e-wallet identifiers, PayID reference)
• Deposit and withdrawal amounts, dates, and transaction IDs
• Currency preferences (Australian Dollar – AUD)
• Bonus usage and balance history

2.3. Technical and Usage Data

• IP address, device type, operating system, and browser version
• Session start and end times, pages visited, and features used
• Geolocation data derived from IP address (country/region level)
• Referral source and affiliate tracking codes

2.4. Communications Data

• Content and metadata of emails, live chat transcripts, and support tickets you send to us
• Records of marketing preferences and opt-in or opt-out decisions
• Feedback, reviews, and survey responses

2.5. Responsible Gaming Data

• Self-exclusion requests and cooling-off elections
• Deposit limits, session limits, and loss limits set by you
• Notifications or flags generated by our responsible gaming monitoring tools

We do not collect sensitive information (such as health data, racial or ethnic origin, or religious beliefs) unless you voluntarily provide it in the context of a responsible gaming or support request, in which case it is handled with the highest level of care and confidentiality.

3. How We Use Your Data

Holspin uses the personal data we collect for specific, legitimate purposes. We do not process your data in any manner that is incompatible with the purposes outlined below.

3.1. Account Management and Service Delivery

We use your registration and identity data to create and maintain your account, verify your age (minimum age: 18 years), process deposits and withdrawals, and communicate important account-related information such as security alerts and policy updates.

3.2. Identity Verification and Fraud Prevention

Your identity documents and financial data are processed to fulfil KYC obligations, detect suspicious activity, prevent money laundering, and comply with anti-fraud requirements. This processing is essential for the integrity of the Platform.

3.3. Customer Support

When you contact our support team, we use your communications data and account history to resolve queries, investigate complaints, and improve service quality. Support interactions may be monitored or recorded for training and quality assurance purposes.

3.4. Responsible Gaming Monitoring

We analyse gameplay patterns, transaction frequency, and responsible gaming tool usage to identify potential indicators of problem gambling. Where such indicators arise, we may proactively reach out or apply protective measures consistent with our Responsible Gaming Policy.

3.5. Marketing and Promotions

With your explicit consent, we may send you personalised promotional offers, newsletters, and information about new games or features via email or other agreed channels. You may withdraw this consent at any time by using the unsubscribe link in any marketing email or by contacting our support team.

3.6. Platform Improvement and Analytics

Technical and usage data help us understand how the Platform performs, identify errors, improve navigation, and develop new features. Analytics are typically processed in aggregated or pseudonymised form.

3.7. Legal and Compliance Obligations

We retain and process certain data to meet record-keeping requirements, respond to lawful requests from regulatory or law-enforcement authorities, and defend or pursue legal claims.

4. Legal Bases for Processing

Every processing activity we carry out rests on at least one of the following recognised legal bases:

Where we rely on legitimate interests, we have balanced those interests against your rights and concluded that the processing is proportionate and does not unduly prejudice your privacy. You may request further information about this balancing assessment by contacting us at the address in Section 13.

5. Data Sharing & Third Parties

Holspin does not sell, rent, or trade your personal data. We share information with third parties only where necessary and under appropriate safeguards.

5.1. Categories of Recipients

• Payment processors and banking partners: Entities that facilitate transactions via Visa, Mastercard, PayID, BPAY, POLi, Skrill, Neteller, PayPal, Neosurf, Paysafecard, Apple Pay, and cryptocurrency gateways. These processors receive only the data needed to complete the transaction and are bound by their own PCI-DSS and data-protection commitments.
• Identity verification providers: Third-party KYC and AML screening services that validate identity documents and screen against sanctions lists.
• Technology and hosting providers: Cloud infrastructure, CDN, and software vendors who process data on our behalf under strict data-processing agreements.
• Analytics and marketing platforms: Service providers that help us measure campaign performance and site usage, operating on pseudonymised or aggregated data wherever possible.
• Regulatory and law-enforcement authorities: We disclose data when required by law, court order, or regulator request.
• Professional advisers: Lawyers, accountants, and auditors who are subject to professional confidentiality obligations.

5.2. Affiliate Partners

If you arrived at the Platform through an affiliate link, we may share limited, non-sensitive data (such as registration confirmation and transaction values) with that affiliate for commission-calculation purposes. Affiliates are contractually prohibited from using this data for any other purpose.

5.3. Business Transfers

In the event of a merger, acquisition, or asset sale, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and the applicable privacy terms before your data is subject to a materially different policy.

6. Cookies & Tracking Technologies

Holspin uses cookies and similar tracking technologies to ensure the Platform functions correctly, to personalise your experience, and to gather analytics data.

6.1. Types of Cookies We Use

• Strictly necessary cookies: Essential for logging in, maintaining session state, and securing the Platform. These cannot be disabled without breaking core functionality.
• Performance and analytics cookies: Collect anonymised information about how visitors use the Platform (e.g., page visit frequency, error reports) to help us improve site performance.
• Functional cookies: Remember your preferences such as language, currency display, and game history to provide a more personalised experience.
• Targeting and advertising cookies: Used (only with your consent) to deliver relevant promotions and to measure the effectiveness of marketing campaigns.

6.2. Managing Your Cookie Preferences

When you first visit the Platform, a cookie consent banner allows you to accept or decline non-essential cookies. You may update your preferences at any time via the cookie settings link in the website footer. You can also control cookies through your browser settings; however, disabling strictly necessary cookies may impair your ability to use the Platform. Note that our use of third-party cookies is governed by the privacy policies of the respective providers.

7. Data Security

We implement a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure.

7.1. Technical Safeguards

• Transport Layer Security (TLS/SSL): All data transmitted between your browser and our servers is encrypted using industry-standard TLS protocols.
• Data encryption at rest: Sensitive data fields, including payment identifiers and identity document references, are encrypted in our databases.
• Access controls: Role-based access controls and multi-factor authentication are enforced for all staff who access personal data.
• Penetration testing and vulnerability scanning: Regular third-party security assessments are conducted to identify and remediate potential weaknesses.
• Firewall and intrusion detection: Network-level controls monitor traffic for suspicious patterns in real time.

7.2. Organisational Safeguards

All team members who handle personal data receive regular privacy and security training. Access to personal data is granted on a need-to-know basis and reviewed periodically. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and any applicable regulatory authority promptly and in accordance with legal requirements.

Despite our best efforts, no system is completely immune to security risks. We encourage you to use a strong, unique password for your Holspin account and to notify us immediately at [email protected] if you suspect any unauthorised access.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law.

8.1. Retention Periods

• Active account data: Retained for the duration of your account relationship with Holspin.
• Transaction and financial records: Retained for a minimum of seven (7) years after the relevant transaction to satisfy financial record-keeping and AML obligations.
• KYC and identity documents: Retained for the period specified by applicable AML regulations following account closure, typically five (5) to seven (7) years.
• Support communications: Retained for up to three (3) years after resolution of the relevant matter.
• Marketing preference records: Retained until you withdraw consent and for a reasonable period thereafter as evidence of your consent decision.
• Technical and log data: Retained for up to twelve (12) months and then purged or anonymised.

Once retention periods expire, personal data is securely deleted or irreversibly anonymised so that it can no longer be attributed to you.

9. Your Rights

As a user of the Platform, you have meaningful rights over your personal data. Holspin is committed to honouring those rights in a timely and transparent manner. The following rights apply to all users, consistent with the Australian Privacy Principles and internationally recognised data-protection standards.

9.1. Right of Access

You may request a copy of the personal data we hold about you. Upon a valid request, we will provide you with a summary of the data, the purposes for which it is processed, the categories of recipients with whom it has been shared, and the applicable retention periods. We will respond within 30 days of receiving a verified request.

9.2. Right to Correction

If any personal data we hold about you is inaccurate, incomplete, or out of date, you have the right to request its correction. You may update basic profile information (such as your address or contact number) directly through your account settings. For changes that require identity re-verification (such as a name correction), please contact our support team.

9.3. Right to Deletion

You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and no other legal basis applies), or where you object to processing and your interests override ours. However, deletion requests may be limited where we are required to retain data to comply with a legal obligation (for example, AML record-keeping requirements) or to defend a legal claim. In such cases, we will inform you of the reason we cannot fully comply.

9.4. Right to Restrict Processing

You may request that we temporarily restrict the processing of your personal data while the accuracy of that data is being contested, while an objection is being evaluated, or where processing is unlawful but you prefer restriction over deletion. During a restriction period, we will continue to store your data but will not actively process it for other purposes.

9.5. Right to Data Portability

Where processing is based on your consent or on the performance of a contract, and the processing is carried out by automated means, you have the right to receive the personal data you provided to us in a structured, commonly used, and machine-readable format, and to request that we transmit it directly to another service provider where technically feasible.

9.6. Right to Object

You have the right to object to processing based on legitimate interests, including profiling for direct marketing purposes. Where you object to direct marketing, we will cease that processing immediately. For other legitimate-interest processing, we will assess whether our interests are overridden by your rights and inform you of the outcome.

9.7. Right to Withdraw Consent

Where processing is based solely on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal. To withdraw consent for marketing communications, use the unsubscribe mechanism in any email or contact us directly.

9.8. How to Exercise Your Rights

To exercise any of the rights described above, submit a written request to [email protected]. We may need to verify your identity before processing your request to prevent unauthorised disclosure. We will not charge a fee for standard requests; however, we reserve the right to charge a reasonable administrative fee for requests that are manifestly unfounded or excessive in frequency.

9.9. Complaints

If you believe we have not handled your personal data in accordance with this Policy, you are encouraged to contact us first so that we have the opportunity to address your concern. If you remain dissatisfied, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

10. International Data Transfers

Holspin operates globally and, as a result, your personal data may be transferred to and stored on servers located outside of Australia. Such transfers may occur when we engage cloud infrastructure providers, KYC verification services, or analytics platforms headquartered or operating in other countries.

10.1. Safeguards for Cross-Border Transfers

Whenever personal data is transferred outside Australia, we implement appropriate safeguards to ensure that your data receives a level of protection consistent with the Australian Privacy Principles. These safeguards may include:

• Contractual clauses that obligate overseas recipients to protect the data in accordance with Australian privacy standards;
• Transfer to jurisdictions that have been assessed as providing substantially similar protections to those available in Australia;
• Technical controls such as encryption during transit and at rest, regardless of where data is stored.

By using the Platform, you acknowledge that your data may be processed in countries outside Australia. If you would like further information about the specific countries involved or the safeguards in place, please contact our Privacy team at [email protected].

11. Minors

The Platform is strictly intended for individuals who are 18 years of age or older. We do not knowingly collect, process, or retain personal data from anyone under the age of 18. Age verification is a mandatory step during the account registration process, and we may request additional documentary evidence to confirm that a user meets the minimum age requirement.

If we become aware that personal data has been collected from a person under 18 without verifiable parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform or that their data has been collected in error, please notify us immediately at [email protected].

Parents and guardians are encouraged to make use of parental control tools and filtering software to prevent minors from accessing online gambling platforms. Additional guidance is available in our Responsible Gaming Policy.

12. Changes to This Policy

Holspin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data-processing practices, legal requirements, or the services we offer. The version number and "Last Updated" date at the top of this page will be revised whenever a material change is made.

For material changes that significantly affect how we process your personal data, we will notify you via email to the address registered on your account, or by displaying a prominent notice on the Platform, at least 14 days before the changes take effect. Your continued use of the Platform after that date constitutes your acceptance of the revised Policy. If you do not agree with the changes, you should cease using the Platform and may request account closure through our support team.

We encourage you to review this Policy periodically. Older versions of this Policy are available on request by contacting [email protected].

13. Contact Information

If you have questions, concerns, or requests relating to this Privacy Policy or our data-processing activities, please reach out to us through one of the following channels:

We aim to acknowledge all privacy-related enquiries within 5 business days and to provide a substantive response within 30 calendar days. Where a request is particularly complex or numerous requests have been received simultaneously, we may extend the response period by a further 30 days, in which case we will inform you of the extension and the reason for it.

For complaints that remain unresolved after engaging with us, you may escalate your concern to the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au | Phone: 1300 363 992.