Who This Policy Covers and Why It Exists
This Privacy Policy applies to all players and visitors who access Topless Casino from New Zealand. It sets out how we collect, store, use, and protect your personal information, and it explains the rights you hold under the Privacy Act 2020 (New Zealand).
Topless Casino is operated from Level 4, 6 Gilmer Terrace, Wellington 6011, New Zealand. We are the data controller for all personal information you share with us when you register, deposit funds, play games, or contact our support team. Any reference to “we”, “us”, or “our” throughout this document refers to Topless Casino.
We are required to comply with the Privacy Act 2020 and its thirteen Information Privacy Principles, the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (the AML/CFT Act), the Gambling Act 2003, and the Unsolicited Electronic Messages Act 2007. This policy is written to reflect those obligations honestly, not to obscure them.
What Personal Information We Collect
Information You Provide Directly
When you create an account or interact with our services, we collect the following categories of information:
- Full legal name, date of birth, and residential address
- Email address and phone number
- Username and encrypted account password
- Payment method details, including card numbers (stored in tokenised form), cryptocurrency wallet addresses, and transaction records
- Copies of identity documents submitted for verification, such as a passport, driver licence, or proof of address
- Responses to any responsible gambling questionnaires or self-assessment tools you complete voluntarily
- Support messages, live chat transcripts, and email correspondence with our team
Information Collected Automatically
When you use our website or mobile application, certain technical information is recorded without you needing to enter it manually:
- IP address and approximate geolocation derived from it
- Device type, operating system, and browser version
- Session duration, pages visited, and features accessed
- Game history, wagering activity, deposit and withdrawal patterns
- Cookies and similar tracking technologies (covered separately in our Cookie Policy)
Information From Third Parties
We may receive information about you from the following external sources:
- Identity verification providers who confirm your documents against official databases
- Payment processors, including Visa, Mastercard, Apple Pay, Google Pay, and cryptocurrency networks, who share transaction confirmation data
- Fraud detection and AML screening services that cross-reference your details against sanctions lists and politically exposed persons registers
- Analytics providers who aggregate behavioural data from our platform
Why We Collect Your Information
Every category of personal data we hold serves a specific purpose. We do not collect information speculatively or hold it beyond the point where a legitimate purpose exists.
Account Management and Service Delivery
We need your name, contact details, and login credentials to create and maintain your account, process deposits and withdrawals, credit bonuses, and ensure you can access your gaming history. Without this information, we cannot operate your account.
Legal Identity Verification
Under the AML/CFT Act 2009 and the regulations made under it, we are required to verify your identity before processing withdrawals above certain thresholds. This is not optional for us or for you. The checks are designed to prevent money laundering and the financing of illegal activity. We use your identity documents solely for this purpose and do not retain copies beyond our legal retention obligations.
Age Verification
The Gambling Act 2003 prohibits gambling by persons under 18 years of age. We collect your date of birth and verify it against official documents to comply with this requirement. Topless Casino is strictly an 18+ platform.
Responsible Gambling Obligations
New Zealand gambling law and our operating licence require us to identify players who may be experiencing harm from gambling. We use your account activity, betting patterns, and session data to support this function. If our monitoring identifies signs of problem gambling, we may contact you directly or apply account restrictions.
Fraud Prevention and Security
We analyse device data, IP addresses, and transaction patterns to detect unauthorised access, duplicate accounts, bonus abuse, and payment fraud. This processing is a legitimate interest that protects both Topless Casino and the integrity of your account.
Marketing Communications
We send promotional emails and notifications about bonuses, new games, and offers only to players who have given explicit consent to receive them. This is consistent with the Unsolicited Electronic Messages Act 2007, which requires opt-in consent for commercial electronic messages. You can withdraw this consent at any time by clicking the unsubscribe link in any marketing email or by contacting us at support@topless-casino-nz.com.
Platform Improvement and Analytics
Aggregated, anonymised data drawn from player behaviour helps us understand how the platform is used, which game categories attract the most engagement, and where the registration or cashier flow causes friction. We use this data to improve the service. It is not linked back to individual player accounts in identifiable form.
How We Handle Your Information
Storage and Security
Your data is stored on servers that use SSL encryption in transit and AES-256 encryption at rest. Access to personal data within our organisation is restricted to staff whose roles require it. All payment card information is stored in tokenised form, meaning the raw card number is never held on our servers after initial processing.
We offer two-factor authentication on player accounts and encourage you to enable it, particularly if you make regular deposits or withdrawals. While we maintain robust technical controls, no system can guarantee absolute security, and we encourage you to use a strong, unique password for your Topless Casino account.
Retention Periods
We keep your personal information for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention requirements:
- Account records and transaction history: retained for seven years after account closure, as required under the AML/CFT Act 2009
- Identity verification documents: retained for five years from the date of the transaction or the end of the business relationship, per AML/CFT regulations
- Responsible gambling records: retained for the duration of any self-exclusion period plus five years
- Marketing consent records: retained until you withdraw consent, plus one year
- Support communications: retained for three years from the date of the interaction
Once a retention period expires, data is either securely deleted or irreversibly anonymised.
Sharing With Third Parties
We do not sell your personal information. We do not share it with advertisers for the purpose of targeting you with third-party commercial messages. Where we share data with third parties, we do so only in the following circumstances and under contractual data protection obligations:
- Payment processors: Visa, Mastercard, Apple Pay, Google Pay, and cryptocurrency network providers receive only the transaction data necessary to process your payments
- Identity verification providers: Your document and biometric data is shared with verification partners solely for the purpose of completing KYC checks required under the AML/CFT Act
- Fraud and AML screening services: We screen account holders against sanctions lists and politically exposed persons registers maintained by recognised providers
- Regulatory authorities: We are required to disclose certain information to the Department of Internal Affairs (which administers New Zealand’s AML/CFT regime) and to the Financial Intelligence Unit on request or as mandated by law
- IT infrastructure providers: Hosting and cloud service providers who maintain our servers operate under strict data processing agreements
International Data Transfers
Some of our service providers are located outside New Zealand. Where personal data is transferred to countries that do not have equivalent privacy protections, we require contractual safeguards that align with the Privacy Act 2020’s requirements for cross-border disclosures. We do not transfer data to jurisdictions without ensuring that appropriate protections are in place.
Your Rights Under the Privacy Act 2020
The Privacy Act 2020 gives you a set of rights in relation to your personal information. We are obligated to honour these rights and to respond to requests within a reasonable time, which we treat as 20 working days from receipt of a verifiable request.
Right of Access
You have the right to ask us what personal information we hold about you and to receive a copy of it. You can make an access request by emailing support@topless-casino-nz.com from the email address registered to your account. We may ask you to verify your identity before processing the request.
Right to Correction
If any personal information we hold about you is inaccurate, incomplete, or misleading, you have the right to ask us to correct it. You can do this directly from your account dashboard for most fields, or by contacting our support team for fields you cannot update yourself.
Right to Complain
If you believe we have handled your personal information in a way that breaches the Privacy Act 2020, you can complain to us first by contacting support. If you are not satisfied with our response, you have the right to complain to the Privacy Commissioner of New Zealand. The Privacy Commissioner’s contact details and complaint process are available at www.privacy.org.nz.
Right to Withdraw Marketing Consent
You can withdraw consent to receive marketing communications at any time. Withdrawal of marketing consent does not affect our right to send you transactional or account-related messages, such as deposit confirmations, withdrawal notifications, or security alerts.
Data Breach Notification
The Privacy Act 2020 requires us to notify the Privacy Commissioner and affected individuals when a privacy breach causes or is likely to cause serious harm. We maintain an internal breach response plan that includes containment procedures, assessment of harm, and timely notification obligations.
If a breach affects your personal information in a way that may cause you serious harm, we will contact you at the email address registered to your account as soon as reasonably practicable after discovering the breach, and no later than required by the Privacy Commissioner’s guidelines.
Cookies and Tracking Technologies
We use cookies and similar technologies to keep you logged in, remember your preferences, analyse platform usage, and measure the performance of our marketing. A full description of the cookies we use, their purposes, and how to manage them is available in our Cookie Policy.
You can adjust cookie preferences through your browser settings at any time. Disabling certain categories of cookies may affect the functionality of your account.
Responsible Gambling and Data Use
Topless Casino operates in accordance with responsible gambling principles. We use account activity data to identify patterns that may indicate gambling-related harm, including rapid increases in deposit frequency, extended session lengths, and repeated attempts to reverse withdrawal requests.
Players can set deposit limits, session time reminders, cooling-off periods, and self-exclusion options directly from their account dashboard. Self-exclusion data is retained and enforced for the full duration of any exclusion period, and requests to lift a self-exclusion before it expires are subject to a mandatory reflection period.
For external support, we partner with Gambling Therapy and BeGambleAware. If you are concerned about your gambling or someone else’s, these services provide free, confidential support.
Children and Minors
Topless Casino does not knowingly collect personal information from anyone under the age of 18. Our registration process requires you to confirm your date of birth, and we verify this through identity documents before processing any withdrawal. If we become aware that an account has been registered by a person under 18, we will close the account immediately, void any balances, and securely delete the associated personal data to the extent permitted by our legal obligations.
If you believe a minor has created an account on our platform, please contact us at support@topless-casino-nz.com or call +64 4 893 6077.
Links to External Websites
Our website contains links to third-party sites including responsible gambling organisations and payment provider information pages. Once you leave topless-casino-nz.com, this Privacy Policy no longer applies. We are not responsible for the privacy practices of external sites and encourage you to review their policies before sharing any personal information with them.
Changes to This Policy
We review this Privacy Policy periodically to reflect changes in law, regulatory guidance, or our business operations. When we make material changes, we will notify registered players by email at the address on file. Continued use of the platform after notification constitutes acceptance of the revised policy. If you do not agree with a change, you should close your account before it takes effect.
How to Contact Us
For any questions about this Privacy Policy, requests to access or correct your personal information, or concerns about how we have handled your data, you can reach us through the following channels:
- Email: support@topless-casino-nz.com
- Phone: +64 4 893 6077
- Post: Topless Casino, Level 4, 6 Gilmer Terrace, Wellington 6011, New Zealand
- Live Chat: Available 24 hours a day, 7 days a week via the chat widget on topless-casino-nz.com
If your concern is not resolved to your satisfaction after contacting us, you may refer the matter to the Office of the Privacy Commissioner of New Zealand at www.privacy.org.nz.