Privacy Policy

This Privacy Policy explains how Golden Reels, operated through the website https://goldenreels-aussie.com, collects, uses, discloses, and protects personal information of players and website visitors. It is designed to comply with applicable privacy and data protection rules relevant to our operations, including Australian privacy principles as a reference standard, while recognising that our operator is based offshore. This Privacy Policy applies to all users who access or use our website, interact with our services, or communicate with us. By using our website, you agree to the practices described in this Policy. This Privacy Policy is effective as of 1 January 2025 and remains in force until updated, with key provisions intended to remain consistent through at least 31 December 2026.

Who We Are

OBSERVE: Golden Reels is a review and gaming services environment operated under the Golden Reels brand via the domain goldenreels-aussie.com. The operational and licensing information is essential to identify the data controller and related entities for privacy purposes.

EXPAND: The core operator, licensing jurisdiction, and payment-processing subsidiary must all be disclosed to provide transparency about which entities may process personal data, including cross-border aspects.

REFLECT: The following information is provided to clearly identify the responsible entities and contact points for privacy matters.

Operator and Legal Entities

• Trading/Brand name: Golden Reels (as presented via Golden Reels on goldenreels-aussie.com).
• Primary operating company (data controller for gaming services): Pompano Industries B.V., a private limited liability company (B.V.) incorporated under the laws of Curaçao.
  • Registration number: 156686
  • Jurisdiction of incorporation: Curaçao
  • Gaming licence: Online gambling sub-licence No. 8048/JAZ issued by Antillephone N.V., Curaçao (status indicated as valid as of 2024-05 and assumed to remain valid through 2026 unless revoked).
  • Corporate address: A precise street address was not provided in the available data. Pompano Industries B.V. is registered in Curaçao; further address details may be obtained on justified request.
• Payment processing entity: Mowlako Ltd, a limited company incorporated in Cyprus, acting as payment processor and related services provider for Golden Reels.
  • Legal address: Chytron, 30, 2nd Floor, Flat/Office A22, 1075, Nicosia, Cyprus
  • Jurisdiction: Cyprus

Contact for Privacy Matters (DPO / Data Protection Function)

• Designated privacy contact: Data Protection Officer (DPO) / Data Protection Department for Golden Reels
• Email (primary for privacy and data protection): [email protected]
• Email (customer support, including privacy-related queries): [email protected]
• Additional contacts:
  • [email protected] - payment-related questions (may involve limited access to transaction data).
  • [email protected] - media inquiries.
  • [email protected] - recruitment and HR matters.
• Postal contact for privacy correspondence (recommended): Mowlako Ltd, Data Protection Officer, Chytron, 30, 2nd Floor, Flat/Office A22, 1075, Nicosia, Cyprus.

Regional Compliance Note: The service targets, among others, users in Australia but is operated and licensed outside Australia. Australian users should be aware that enforcement actions, including ACMA blocking orders under the Interactive Gambling Act 2001 (e.g., ACMA Blocking Order No. 45, 2023 in relation to Golden Reels), do not change the fact that personal data is primarily processed under Curaçao and Cyprus laws, supplemented by international standards and best practices.

What Personal Data We Collect

OBSERVE: To provide online gambling and review-related services via goldenreels-aussie.com, Golden Reels and its operator must collect several categories of data: identification, contact, transactional, technical, and behavioural information, as well as cookie data.

EXPAND: These categories reflect the minimum information necessary to run user accounts, comply with anti-fraud and AML requirements, administer payments, and improve the service experience, while maintaining appropriate security.

REFLECT: Below we categorise the personal data we collect and provide examples for transparency. Not all categories will apply to every user.

Identity and Contact Data

• Identification data: full name, date of birth, gender (where provided), username or account ID, copies or details of identity documents (passport, driver's licence, national ID) where required for verification.
• Contact details: email address, telephone number (mobile and/or landline), residential address, billing address, communication language preferences.
• Account information: profile settings, security questions and answers, communication preferences for marketing or service messages.

Technical and Usage Data

• Technical identifiers: IP address, device identifiers, browser type and version, operating system, screen resolution, time zone setting, approximate location inferred from IP.
• Log data: access dates and times, pages viewed, referral URLs, clickstream data, error logs, login/logout events, session duration, network diagnostics.
• Device data: device model, hardware information, language settings, mobile network information where relevant.

Payment and Financial Data

• Payment details: limited cardholder information (such as card type, masked card number, card expiry date), e-wallet identifiers, bank transfer references, and details required by our payment processors (through Mowlako Ltd and other partners).
• Transaction history: deposits, withdrawals, bonuses claimed, chargebacks, reversals, payment disputes, currency, and transaction timestamps.
• AML/KYC data: verification results, sanctions screening results, source-of-funds or source-of-wealth information where collected, and internal risk ratings.

Behavioural and Service Use Data

• Gaming and betting data: game sessions, bets placed, wins and losses, game preferences, time spent playing, bonus usage, tournament participation.
• Website interaction data: pages visited on goldenreels-aussie.com, clicks on banners and links, navigation paths, searches performed, interactions with customer support tools and live chat.
• Marketing interaction data: email opens, link clicks within emails or push notifications, unsubscribe actions, participation in promotions or surveys.

Communications and Support Data

• Customer support interactions: emails with [email protected] or [email protected], live chat transcripts, recorded calls where authorised by law, complaint details, and resolutions.
• Feedback and content: responses to surveys, reviews or ratings, and other content you voluntarily submit via forms (where available) or communications.

Cookies and Similar Technologies

• Cookies: small text files stored on your device to remember your preferences, maintain sessions, and collect analytics data.
• Similar technologies: web beacons, pixels, local storage, and SDKs used for analytics, performance monitoring, and advertising attribution.
• Cookie data collected: cookie identifiers, associated device and session IDs, timestamped events, preferences (language, currency, game filters), and anonymised usage metrics.

Where we collect data that is not directly identifiable (e.g., aggregated or anonymised statistics), we take reasonable steps to ensure such data cannot be re-linked to an identifiable individual, except where re-identification is required for security, legal, or regulatory reasons.

Legal Basis for Processing

OBSERVE: As Golden Reels operates from jurisdictions such as Curaçao and Cyprus and interacts with users from multiple regions, the processing of personal data is grounded in a combination of contract necessity, consent, legitimate interests, and legal obligations.

EXPAND: Although we are not established in the EU or Mexico, we align key practices with the principles found in the EU General Data Protection Regulation (GDPR) and comparable international standards as a benchmark for fair processing.

REFLECT: The main legal bases (or equivalent justifications) for processing your data are as follows.

Performance of a Contract

• Account creation and management: We process identity, contact, and technical data to register and manage your account, authenticate you, and provide access to games and related services.
• Provision of gambling and related services: We process gameplay, betting, and transaction data to operate games, record bets, calculate and pay winnings, apply bonuses, and manage account balances.
• Customer service: We use your data to respond to queries, provide technical support, and handle complaints or disputes, including via email and other communication channels.

Compliance with Legal and Regulatory Obligations

• KYC and AML requirements: We process identity, payment, and AML/KYC data to verify your identity, prevent money laundering and terrorist financing, and fulfil record-keeping obligations imposed by our licensing and financial partners.
• Gambling regulation: We use your behavioural and transactional data to comply with licensing duties under Curaçao law and relevant guidance, including responsible gambling and anti-fraud measures.
• Taxation and accounting: We retain and process transaction data for accounting, auditing, and potential tax-reporting obligations in relevant jurisdictions.
• Legal claims and enforcement: We may process data where necessary to establish, exercise, or defend legal claims, to respond to lawful requests by authorities, or to enforce our Terms and Conditions.

Legitimate Interests

• Service security and integrity: We process technical, log, and behavioural data to protect our systems, prevent unauthorised access, detect fraud and abuse, and ensure network and information security.
• Service improvement and analytics: We analyse aggregated and pseudonymised data to develop new features, optimise our games and website, and understand trends in user behaviour.
• Internal business administration: We use data for internal reporting, management of relationships with payment providers and game suppliers, and for planning and compliance monitoring.

Consent

• Direct marketing: We rely on your explicit consent (e.g., opt-in checkbox, account preference) to send you promotional emails, SMS or push notifications where required by applicable law. You may withdraw consent at any time through the unsubscribe link or account settings.
• Non-essential cookies and tracking: Where required, we obtain your consent for analytics and advertising cookies or similar technologies, particularly for personalised marketing.
• Special categories of data: In the rare event we collect sensitive data (for example, information regarding problem-gambling self-exclusion or health-related notes shared with support), we do so only with your consent or where strictly necessary to protect your vital interests or fulfil legal obligations.

Purpose of Processing

OBSERVE: Each category of personal data is collected for specific, clearly defined purposes consistent with lawful and fair processing.

EXPAND: These purposes span service provision, customer support, compliance, risk management, analytics, marketing (where permitted), and responsible gambling.

REFLECT: The purposes below describe how and why we use your information.

Service Provision and Account Management

• To register, verify, and maintain your user account on goldenreels-aussie.com.
• To provide access to games, betting opportunities, promotions, and related services offered under the Golden Reels brand.
• To manage financial transactions, including deposits, withdrawals, payment reconciliations, and bonuses.

Customer Support and Communication

• To respond to your queries and requests sent to [email protected], [email protected], or other channels.
• To notify you of important changes to our services, Terms and Conditions, or this Privacy Policy.
• To communicate about service disruptions, technical issues, security alerts, and account-related events.

Compliance, Risk Management, and Fraud Prevention

• To verify your identity and eligibility, perform KYC checks, and comply with AML/CTF obligations.
• To detect and prevent fraud, money laundering, bonus abuse, account takeover, and other prohibited activities.
• To investigate suspicious or potentially illegal behaviour and cooperate with law enforcement or regulators where required.

Analytics, Service Improvement, and Personalisation

• To analyse aggregated usage and transaction data to improve our games, website performance, user interface, and product offerings.
• To develop new features and measure the effectiveness of campaigns, promotions, and changes to the platform.
• To tailor content and recommendations (e.g., game suggestions) based on your historical preferences and behaviour, where allowed by law and your settings.

Marketing and Promotions

• To send you promotional communications about bonuses, tournaments, new games, and special offers, subject to your marketing preferences and applicable consent requirements.
• To measure and optimise the effectiveness of marketing communications, affiliates, and advertising networks.
• To conduct surveys, competitions, and loyalty programs, and to notify winners where applicable.

Responsible Gambling and Player Protection

• To monitor playing patterns and behaviour for indicators of problematic gambling where our systems and regulatory frameworks require or support such monitoring.
• To implement self-exclusion, limits, and other responsible-gambling tools you choose to activate.
• To maintain records necessary to respect self-exclusion and similar protection measures.

Disclosure & Sharing

OBSERVE: To operate effectively, Golden Reels and Golden Reels must share personal data with carefully selected third parties under contractual safeguards.

EXPAND: These disclosures concern payment processors, technical service providers, regulators, affiliates, and, where you consent, advertising networks and marketing partners.

REFLECT: We detail below the categories of recipients, the purposes of such sharing, and the associated protections.

Group Companies and Operational Partners

• Operator and payment entities: Pompano Industries B.V. and Mowlako Ltd share and access personal data strictly for operational, compliance, and payment processing purposes related to Golden Reels services.
• Game providers: Software suppliers (e.g., studios whose RNGs are certified, such as Pragmatic Play with GLI certification) may receive limited pseudonymised identifiers and game-event data to run games and resolve technical issues, not for independent marketing.

Payment Service Providers and Financial Institutions

• We share identification, payment, and transaction data with banks, card schemes, e-wallet providers, and other payment intermediaries to process deposits, withdrawals, and refunds.
• These providers act as independent controllers or processors depending on the specific service and applicable law, and are bound by financial regulations and confidentiality duties.

Service Providers and Contractors

• IT and hosting providers: We use secure hosting, cloud, and infrastructure providers to store and process data, subject to strict security and contractual obligations.
• Analytics and customer support tools: We may use third-party platforms for analytics, customer relationship management, email delivery, and live chat to support communications and improve services.
• Professional advisers: Lawyers, auditors, consultants, and compliance advisers may access personal data as necessary to provide services under confidentiality obligations.

Regulators, Authorities, and Dispute Bodies

• We may disclose personal data to gaming regulators, financial intelligence units, tax authorities, law enforcement agencies, or courts in Curaçao, Cyprus, or other relevant jurisdictions when legally required or to protect our rights.
• We may cooperate with Australian authorities such as the Australian Communications and Media Authority (ACMA) in relation to enforcement actions (e.g., blocking orders) where we are required or encouraged to do so under applicable international cooperation frameworks.

Affiliates and Advertising Networks

• Affiliates: We may share limited pseudonymised data (such as tracking IDs) with affiliate partners to attribute referrals and manage commission structures.
• Advertising networks and marketing partners: With your consent where required, we may use cookies, identifiers, and aggregated usage data for targeted advertising, retargeting, and campaign measurement through advertising networks.

Business Transfers

• In the event of a merger, acquisition, sale of assets, restructuring, or insolvency involving Pompano Industries B.V., Mowlako Ltd, or Golden Reels, personal data may be transferred to the relevant successor entities or acquirers, subject to continued protection consistent with this Privacy Policy.

Legal Protections

• We may disclose personal data where we reasonably believe it is necessary to:
  • Comply with applicable law, regulations, or legal processes;
  • Enforce our Terms and Conditions or other agreements;
  • Protect the rights, property, or safety of Golden Reels, our customers, or the public.

International Transfers

OBSERVE: Data collected through goldenreels-aussie.com is processed primarily in Curaçao and Cyprus, but may be transferred to other jurisdictions where our service providers or infrastructure are located.

EXPAND: Many of these jurisdictions may not have the same level of data protection as your home country. Appropriate safeguards and contractual protections are therefore necessary.

REFLECT: We describe the main transfer routes and protections used.

Locations of Processing

• Curaçao: Primary licensing and operational jurisdiction of Pompano Industries B.V.
• Cyprus: Location of Mowlako Ltd, providing payment processing and related services.
• European Economic Area (EEA) and United Kingdom: Certain cloud, hosting, analytics, or service providers may process data in these regions.
• Other jurisdictions: Subject to business needs, technical support and backup services may be provided from additional countries, including but not limited to the United States or other international locations.

Safeguards for International Transfers

• Contractual protections: Where required, we implement standard contractual clauses (SCCs) or equivalent contractual mechanisms to ensure an adequate level of protection for cross-border transfers from regions such as the EEA or UK.
• Technical and organisational measures: We apply encryption, access controls, and security standards to protect data during and after transfer, regardless of destination.
• Risk assessment: Before engaging new overseas service providers, we assess the legal and security environment of the destination country and implement mitigation measures where necessary.

Regional Compliance Note (AU): Because processing typically occurs outside Australia, Australian privacy and telecommunications authorities (including ACMA) may have limited direct oversight of data handling. By using the service, you acknowledge that your information may be transferred and processed outside Australia under the safeguards described above.

Data Retention

OBSERVE: Personal data should not be kept longer than necessary for the purposes for which it was collected, subject to legal and regulatory record-keeping obligations.

EXPAND: Gambling and financial regulations, AML rules, and potential dispute timeframes require retention of certain data for extended periods, often several years after account closure.

REFLECT: We adopt the retention principles below, with specific periods applied where practical and subject to ongoing review up to at least 2026.

General Retention Principles

• We retain personal data only for as long as necessary to:
  • Provide services and manage your account;
  • Comply with legal obligations (e.g., AML, accounting, tax, gambling regulations);
  • Resolve disputes and enforce our agreements.
• Where data is no longer required, we will either securely delete it or irreversibly anonymise it.

Indicative Retention Periods

• Account and identification data: Typically retained for the duration of the account and for up to 5 - 7 years after account closure, depending on applicable AML and gambling regulations.
• Transaction and payment data: Retained for at least 5 years from the last transaction date, and potentially longer where required for tax or legal purposes.
• Gameplay and betting history: Retained for the life of the account and at least 5 years after closure to enable dispute resolution, responsible gambling reviews, and compliance audits.
• Customer support communications: Retained for 3 - 5 years after the last interaction, subject to ongoing disputes or investigations.
• Marketing data: Retained until you withdraw consent or object to processing; records of your opt-out choices may be kept for a longer period to ensure your preferences are respected.
• Cookies and analytics data: Retention periods vary by cookie type, typically from the end of the browsing session (for session cookies) up to 24 months (for persistent analytics cookies), in accordance with our Cookies section.

Deletion and Anonymisation

• When retention periods expire, or when data is no longer needed, we will:
  • Securely delete or destroy personal data; or
  • Irreversibly anonymise data for statistical or analytical purposes.
• Certain data may be retained in secure backups for limited periods beyond the active retention timeframe, after which it is overwritten or destroyed in line with our backup policies.

Your Rights

OBSERVE: Users should be able to understand and, where applicable, exercise privacy rights such as access, rectification, deletion, restriction, objection, and data portability, as recognised under modern privacy frameworks like the GDPR and comparable regulations.

EXPAND: Although Golden Reels is not formally subject to EU GDPR or Mexican data protection laws, we endeavour to align with their core principles where operationally feasible, while recognising that some rights may be limited by our regulatory obligations (e.g., AML retention) and jurisdictional constraints.

REFLECT: The rights described below are applied in good faith, subject to authentication and legal limitations.

Access to Your Data

• You may request confirmation as to whether we process your personal data and obtain a copy of such data, subject to reasonable limitations.
• Where feasible, we will provide:
  • Categories of data processed;
  • Purposes of processing;
  • Categories of recipients;
  • Retention periods or relevant criteria.

Correction (Rectification)

• You have the right to request correction of inaccurate or incomplete personal data about you.
• In many cases, you may update certain profile details directly within your account interface; otherwise, you may contact us via [email protected] or [email protected].

Deletion (Erasure)

• You may request deletion of your personal data where:
  • It is no longer necessary for the purposes for which it was collected;
  • You withdraw consent (where consent is the sole basis); or
  • You believe our processing is unlawful and no overriding legal obligations apply.
• We may refuse or delay deletion where retention is required by AML, gambling, accounting, tax, or other legal obligations or where data is necessary for legal claims.

Restriction of Processing

• You may request that we restrict processing of your data (other than storage) where:
  • You contest the accuracy of the data (pending verification);
  • Processing is unlawful but you prefer restriction to deletion; or
  • We no longer need the data but you require it for legal claims.

Objection to Processing

• You may object to processing of your data based on our legitimate interests, particularly for direct marketing purposes.
• If you object to direct marketing, we will stop such processing without undue delay.
• For other legitimate-interest processing, we will assess your objection and either:
  • Cease processing; or
  • Demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or processing required for legal claims.

Data Portability

• Where technically feasible and subject to applicable law, you may request that we provide certain data you have provided to us in a structured, commonly used, and machine-readable format, or transmit it to another controller.
• This typically applies to data processed based on consent or contract through automated means, such as core account and transactional information.

Withdrawal of Consent

• If we rely on your consent to process personal data, you may withdraw that consent at any time, without affecting the lawfulness of processing prior to withdrawal.
• You may withdraw consent to marketing communications by using the unsubscribe link in emails, updating your account preferences (where available), or contacting [email protected].

Exercising Your Rights and Response Timeframes

• How to submit a request:
  • Email our DPO/data protection team at [email protected]; or
  • Contact customer support at [email protected] clearly stating your request.
• Verification: We may request additional information to verify your identity before acting on your request, particularly for sensitive data or financial information.
• Response time: We aim to respond to all valid requests within 30 calendar days of receipt and verification. For complex or multiple requests, this period may be extended by a further 30 days; if so, we will notify you.
• Charges: Requests are generally free of charge. We may charge a reasonable fee or refuse to act where a request is manifestly unfounded, repetitive, or excessive, consistent with international privacy standards.

Note: While we align our practices with GDPR-style and comparable frameworks, your legal rights and available remedies will ultimately depend on the laws of the jurisdiction that apply to our relationship, which may not formally include EU or Mexican data protection regulations.

Cookies & Tracking Technologies

OBSERVE: goldenreels-aussie.com uses cookies and similar technologies to operate the website, recognise returning users, analyse usage, and tailor content and advertising.

EXPAND: These technologies are categorised by purpose (e.g., strictly necessary, functional, analytics, advertising) and duration (session or persistent), and may involve first- and third-party providers.

REFLECT: Below we explain the types used and how you can manage them.

Types of Cookies We Use

• Session cookies: Temporary cookies that exist only while your browser is open and are automatically deleted when you close it. Used for login sessions, navigation, and secure operation of the site.
• Persistent cookies: Remain on your device for a defined period or until deleted. Used to remember your preferences (e.g., language, currency, game filters) and to recognise you on return visits.
• First-party cookies: Set by goldenreels-aussie.com to support core functionality, security, and internal analytics.
• Third-party cookies: Set by external providers (e.g., analytics, advertising networks, affiliate trackers) to measure traffic, campaign performance, and, where permitted, to support personalised advertising.

Purposes of Cookies

• Strictly necessary / functional: Required for basic site operation, security, session management, and access to secure account areas. These cannot generally be disabled without affecting site functionality.
• Performance and analytics: Help us understand how visitors use the site, which pages are most popular, how users move through the site, and where errors occur, so we can improve user experience.
• Advertising and marketing: Used to deliver and measure advertising, limit the number of times you see an ad, and help us and our partners display content that is more relevant to your interests, subject to applicable consent requirements.

Managing Cookies

• Browser settings: Most web browsers allow you to:
  • View which cookies are stored on your device;
  • Delete cookies;
  • Block cookies from specific sites; and
  • Block all cookies from being set.
• Blocking or deleting cookies may impact your ability to use some features, including login sessions and personalised settings.
• Consent tools: Where required by applicable law, we will present a cookie banner or preference tool that allows you to accept or reject non-essential cookies.

Data Security

OBSERVE: Protecting the confidentiality, integrity, and availability of personal data is a core requirement for an online gambling operator handling financial and behavioural data.

EXPAND: Security measures must address data in transit and at rest, user authentication, access controls, monitoring, and incident response, as well as staff awareness.

REFLECT: We implement a layered security approach that draws upon internationally recognised best practices and standards.

Technical Security Measures

• Encryption in transit: Data transmitted between your browser and goldenreels-aussie.com is protected using TLS 1.2+ encryption, helping to prevent interception and tampering.
• Encryption at rest: Where appropriate, sensitive data (including credentials and payment-related tokens) is stored using strong encryption or hashing with salted algorithms.
• Access controls: Personal data is accessible only to authorised personnel and service providers on a need-to-know basis, enforced through role-based access and authentication measures.
• System hardening: Servers and applications are regularly patched and configured to reduce attack surfaces, supported by firewalls and intrusion detection tools.

Organisational and Procedural Measures

• Policies and training: Staff involved in handling personal data receive training on confidentiality, data protection, and security best practices, and are bound by confidentiality obligations.
• Vendor management: Third-party providers are subject to due diligence and contractual commitments addressing data protection and security standards.
• Monitoring and audits: System activity and access logs are monitored for unusual patterns, and periodic security reviews are undertaken. Where feasible, we benchmark our practices against international standards such as ISO/IEC 27001 and SOC 2 principles, though formal certification may not be held by every entity involved.

Incident Response

• We maintain incident response procedures to:
  • Identify and assess suspected security incidents involving personal data;
  • Contain and remediate such incidents;
  • Evaluate and mitigate potential impacts on affected individuals.
• Where required by applicable law and where we have reliable contact details, we will notify relevant authorities and affected users of a data breach without undue delay, providing information about the nature of the breach, likely consequences, and measures taken.

Security Responsibility: While we work to protect your information, you are also responsible for maintaining the confidentiality of your login details, using strong passwords, and promptly notifying us of any suspected account compromise.

Complaints & Contacts

OBSERVE: Users must have clear channels to raise questions, exercise rights, or lodge complaints about data protection practices.

EXPAND: A structured procedure helps ensure timely and consistent handling of requests and complaints, and indicates possible escalation paths to supervisory bodies, even where jurisdictional reach may be limited.

REFLECT: The following mechanisms are available to you.

Contacting Us

• Primary privacy contact (DPO/Data Protection Team):
  • Email: [email protected]
  • Postal: Data Protection Officer, Mowlako Ltd, Chytron, 30, 2nd Floor, Flat/Office A22, 1075, Nicosia, Cyprus
• Customer support (including privacy-related issues):
  • Email: [email protected]

Internal Complaint Procedure

1. Submission: Send your complaint or query, clearly labelled as a "Privacy / Data Protection Complaint", to [email protected] or [email protected].
2. Acknowledgement: We aim to acknowledge receipt within 7 business days.
3. Assessment: The DPO or designated privacy lead will review your complaint, gather relevant information, and, if necessary, contact you for clarification.
4. Response: We aim to provide a substantive response within 30 calendar days of receiving all necessary information. For complex matters, we may extend this period, notifying you of the reasons and expected timeline.
5. Resolution: Where we agree that corrective action is required, we will inform you of the steps we intend to take and the expected timeframe.

External Escalation Options

Depending on your location and applicable law, you may have the right to lodge a complaint with a data protection authority or other regulator. Because Golden Reels is operated under Curaçao licensing with payment operations in Cyprus, the primary supervisory contacts may include:

• Curaçao authorities: For matters related to licensing and operations, you may contact the relevant Curaçao gaming or supervisory authorities as indicated on the Antillephone N.V. website or other official Curaçao regulatory portals.
• Cyprus data protection authority: For issues related to processing performed by Mowlako Ltd, you may consider contacting the Office of the Commissioner for Personal Data Protection (Cyprus) using the contact details available on its official website.
• Australian authorities (information only): Australian users may lodge complaints regarding prohibited gambling services and related issues with the Australian Communications and Media Authority (ACMA). While ACMA's jurisdiction over offshore data protection practices is limited, its website (https://www.acma.gov.au) provides guidance and complaint channels, including information about blocking orders such as ACMA Blocking Order No. 45, 2023 concerning Golden Reels.

Your ability to obtain direct enforcement or specific remedies will depend on the laws and jurisdiction applicable to our relationship and to the entities involved.

Updates

OBSERVE: Privacy laws, technological practices, and our business operations can change over time, requiring updates to this Privacy Policy.

EXPAND: Users must be informed about significant changes, provided with reasonable notice where practical, and allowed to make informed decisions about continued use of the service.

REFLECT: We maintain version control and communication mechanisms as outlined below.

Policy Changes and Version Control

• This Privacy Policy may be updated from time to time to reflect:
  • Changes in legal or regulatory requirements;
  • Updates to our services, technologies, or business structure;
  • Feedback from users or supervisory authorities.
• Each version will be identified by a "Last updated" date at the end of the document.
• Last updated: November 2025 (with provisions intended to remain valid through at least the end of 2026 unless materially amended earlier).

Notification of Material Changes

• For material changes that significantly affect how we process your personal data, we will, where reasonably practicable:
  • Notify you by email to the address associated with your account; and/or
  • Display a prominent notice or banner on goldenreels-aussie.com; and/or
  • Provide an alert in your account dashboard (if available).
• We will seek to provide at least 30 days' advance notice of significant changes, unless immediate changes are required by law or to address urgent security or operational issues.

Your Options Following Changes

• Continued use of the website and services after the effective date of updated terms generally constitutes acceptance of the updated Privacy Policy.
• If you do not agree with material changes, you may:
  • Adjust your privacy or cookie preferences where such tools are provided; and/or
  • Request account closure and, where applicable, the exercise of your data protection rights as described in the "Your Rights" section.

For further information about this Privacy Policy or any data protection question related to Golden Reels and Golden Reels services on goldenreels-aussie.com, please contact our Data Protection Officer at [email protected].