Privacy Policy

Last Updated: November 2025

At Thalvion Citadel, we are committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, store, and protect your data in compliance with New Zealand's Privacy Act 2020 and the European Union's General Data Protection Regulation (GDPR).

1. Information We Collect

Personal Information:

When you register or use our Platform, we may collect:

• Name and email address
• Date of birth (to verify you are 18+)
• Username and password
• Contact preferences
• Country of residence

Automatically Collected Information:

• IP address and device information
• Browser type and version
• Operating system
• Pages visited and time spent on the Platform
• Gameplay statistics (virtual coins used, games played)
• Cookies and similar technologies (see our Cookie Policy)

Optional Information:

• Profile information you choose to provide
• Communication preferences
• Feedback and survey responses

2. How We Use Your Information

We use your personal information for the following purposes:

To Provide Our Service:

• Create and manage your account
• Provide access to games and features
• Process Virtual Coin transactions (if applicable)
• Track gameplay and maintain your progress

To Communicate With You:

• Send account-related notifications
• Respond to your inquiries and support requests
• Send updates about new features (with your consent)
• Provide important safety and legal notices

To Improve Our Platform:

• Analyze usage patterns and trends
• Improve game performance and user experience
• Develop new features and content
• Conduct research and analytics

To Ensure Safety and Compliance:

• Verify age requirements (18+)
• Detect and prevent fraud or abuse
• Comply with legal obligations
• Enforce our Terms and Conditions
• Monitor responsible gaming practices

3. Legal Basis for Processing (GDPR)

Under GDPR, we process your data based on:

• Contractual Necessity: To provide the services you requested
• Consent: When you agree to receive marketing communications
• Legitimate Interests: To improve our services and ensure platform security
• Legal Obligation: To comply with applicable laws (e.g., age verification)

4. How We Share Your Information

We do not sell your personal information. We may share your data with:

Service Providers:

• Hosting and cloud storage providers
• Analytics and performance monitoring services
• Customer support platforms
• Payment processors (if applicable)

Legal Requirements:

• When required by law or legal process
• To protect our rights and property
• To enforce our Terms and Conditions
• In connection with regulatory compliance

Business Transfers:

• In the event of a merger, acquisition, or sale of assets

All third parties are required to maintain the confidentiality and security of your data.

5. Your Privacy Rights

Under New Zealand Privacy Act 2020 and GDPR, you have the right to:

• Access: Request a copy of the personal information we hold about you
• Rectification: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your personal information (right to be forgotten)
• Restriction: Request restriction of processing in certain circumstances
• Data Portability: Receive your data in a structured, commonly used format
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent for marketing communications at any time
• Lodge a Complaint: Contact your local data protection authority

To exercise any of these rights, contact us at: privacy@thalvioncitadel.com

6. Data Retention

We retain your personal information for as long as necessary to:

• Provide our services
• Comply with legal obligations
• Resolve disputes
• Enforce our agreements

Typically, we retain account data for the duration of your active account plus 2 years after account closure, unless a longer retention period is required by law.

7. Data Security

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

• Encryption of data in transit and at rest
• Secure server infrastructure
• Access controls and authentication
• Regular security audits and updates
• Employee training on data protection

However, no method of transmission or storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

8. International Data Transfers

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

• Standard contractual clauses
• Adequacy decisions by relevant authorities
• Other legally approved transfer mechanisms

9. Children's Privacy

Age Restriction: Our Platform is strictly for users 18 years and older. We do not knowingly collect information from individuals under 18. If we become aware that a user is under 18, we will immediately delete their account and information.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience. For detailed information about our use of cookies, please see our Cookie Policy.

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

11. Third-Party Links

Our Platform may contain links to third-party websites (e.g., responsible gaming resources). We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

12. Marketing Communications

With your consent, we may send you:

• Updates about new games and features
• Special promotions (virtual coins offers)
• Platform news and announcements

You can opt out of marketing emails at any time by:

• Clicking the "unsubscribe" link in any email
• Updating your account preferences
• Contacting us at support@thalvioncitadel.com

Note: You cannot opt out of essential service communications.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will:

• Post the updated policy on this page
• Update the "Last Updated" date
• Notify you of material changes via email or Platform notification

Your continued use of the Platform after changes constitutes acceptance of the updated policy.

14. Responsible Gaming and Privacy

As part of our commitment to responsible gaming, we may use your data to:

• Monitor gameplay patterns that may indicate problematic behavior
• Provide access to self-exclusion tools
• Offer responsible gaming resources

If you need help with gambling concerns: Gambling Helpline NZ: 0800 654 655

15. Contact Us

If you have questions about this Privacy Policy or how we handle your data, please contact us:

Email: privacy@thalvioncitadel.com
General Support: support@thalvioncitadel.com
Platform: Thalvion Citadel Limited, New Zealand

For GDPR-related inquiries: If you are in the EU and have concerns about how we process your data, you have the right to lodge a complaint with your local supervisory authority.

For New Zealand Privacy Act inquiries: You can contact the Office of the Privacy Commissioner: www.privacy.org.nz