Privacy Policy

1. Introduction

XylaronSanctum Ltd. ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our social casino entertainment platform.

This policy complies with the New Zealand Privacy Act 2020 and incorporates principles from the European Union's General Data Protection Regulation (GDPR) to ensure the highest standards of data protection.

By using XylaronSanctum, you consent to the data practices described in this policy.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily provide when you:

• Create an Account: Email address, username, password, date of birth (for age verification)
• Contact Us: Name, email address, message content, subject of inquiry
• Participate in Surveys: Responses to feedback forms and surveys
• Use Social Features: Profile information, avatars, display names

2.2 Information Collected Automatically

When you use our Platform, we automatically collect certain information:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, games played, time spent on platform, virtual currency activity
• Cookies and Similar Technologies: See our Cookie Policy for details
• Log Data: Server logs, error reports, performance data

2.3 Information We Do NOT Collect

We do not collect or process:

• Payment information (as our platform is completely free)
• Banking details or financial account information
• Social security numbers or government-issued ID numbers
• Information about real money gambling activities

3. How We Use Your Information

We use collected information for the following purposes:

3.1 Platform Operation

• Provide and maintain the Platform services
• Process account registration and authentication
• Enable game functionality and virtual currency management
• Facilitate social features and community interaction

3.2 Improvement and Development

• Analyze usage patterns to improve user experience
• Develop new features and games
• Conduct research and analytics
• Test platform performance and stability

3.3 Communication

• Respond to inquiries and support requests
• Send important platform updates and notifications
• Provide information about new games or features (with consent)
• Send responsible gaming reminders and resources

3.4 Safety and Security

• Verify user age (18+ requirement)
• Prevent fraud and abuse
• Enforce Terms and Conditions
• Protect against security threats
• Monitor for responsible gaming concerns

3.5 Legal Compliance

• Comply with New Zealand laws and regulations
• Respond to legal requests and prevent harm
• Maintain compliance with Gambling Act 2003

4. Legal Basis for Processing (GDPR)

For users in regions covered by GDPR, we process personal data based on:

• Consent: When you provide explicit consent for specific purposes
• Contract Performance: To provide Platform services you've requested
• Legal Obligation: To comply with applicable laws and regulations
• Legitimate Interests: For platform improvement, security, and fraud prevention

5. Information Sharing and Disclosure

5.1 We DO Share Information With:

• Service Providers: Third-party companies that help operate our Platform (hosting, analytics, customer support)
• Legal Authorities: When required by law or to protect rights and safety
• Business Transfers: In connection with mergers, acquisitions, or asset sales (with notice)

5.2 We DO NOT:

• Sell your personal information to third parties
• Share your data for third-party marketing without consent
• Disclose information to gambling operators or real money gaming platforms
• Provide personal data to data brokers

6. Data Retention

We retain personal information for as long as necessary to:

• Maintain your account and provide services
• Comply with legal obligations (minimum 7 years for business records under NZ law)
• Resolve disputes and enforce agreements
• Maintain responsible gaming records

After account deletion, we may retain anonymized data for analytics and legal compliance.

7. Your Privacy Rights

7.1 Rights Under New Zealand Privacy Act 2020

You have the right to:

• Access: Request copies of your personal information
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your personal information
• Restrict Processing: Request limitations on how we use your data
• Complain: Lodge complaints with the NZ Privacy Commissioner

7.2 Additional Rights Under GDPR (If Applicable)

• Data Portability: Receive your data in a portable format
• Object to Processing: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent at any time where processing is based on consent
• Automated Decision-Making: Not be subject to decisions based solely on automated processing

7.3 Exercising Your Rights

To exercise any of these rights, contact us at: support@xylaronsanctum.com

We will respond to requests within 20 working days (NZ Privacy Act) or 30 days (GDPR).

8. Data Security

We implement appropriate technical and organizational measures to protect your personal information:

• Encryption: SSL/TLS encryption for data transmission
• Access Controls: Restricted access to personal data on need-to-know basis
• Secure Storage: Protected servers with regular security updates
• Monitoring: Continuous monitoring for security threats
• Staff Training: Regular privacy and security training for employees

However, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance user experience, analyze usage, and improve our Platform. For detailed information about cookies, please see our Cookie Policy.

You can control cookies through your browser settings, but this may affect Platform functionality.

10. Children's Privacy

XylaronSanctum is strictly for users aged 18 and over. We do not knowingly collect personal information from individuals under 18.

If we discover we have collected information from someone under 18, we will delete it immediately.

If you believe a minor has provided personal information to us, please contact: support@xylaronsanctum.com

11. International Data Transfers

Your information may be transferred to and processed in countries other than New Zealand. When we transfer data internationally, we ensure appropriate safeguards are in place:

• Standard Contractual Clauses (for GDPR compliance)
• Adequate protection measures under NZ Privacy Act
• Service provider agreements with privacy commitments

12. Third-Party Links

Our Platform may contain links to third-party websites (such as support organizations). We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

13. Changes to Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date.

Significant changes will be communicated via:

• Email notification to registered users
• Prominent notice on the Platform
• In-platform notifications

Continued use of the Platform after changes constitutes acceptance of the updated policy.

14. Contact Information

For privacy-related questions, concerns, or to exercise your rights, contact us:

Email: support@xylaronsanctum.com

Subject Line: Privacy Inquiry

Company: XylaronSanctum Ltd.
New Zealand

15. Supervisory Authorities

If you have concerns about how we handle your personal information, you may contact:

New Zealand Privacy Commissioner
Website: www.privacy.org.nz
Phone: 0800 803 909
Email: enquiries@privacy.org.nz

16. Consent

By using XylaronSanctum, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.