Privacy Policy

This Privacy Policy outlines how highrollers-nz.com ("high-roller", "we", "us", "our") collects, uses, discloses, and protects your personal information. It applies to all players and visitors accessing our website or services from New Zealand and globally. The policy is effective as of 6 November 2025 and governs your use of highrollers-nz.com in accordance with applicable privacy laws and industry standards.

Who We Are

OBSERVE: The legal operator of highrollers-nz.com is Happy Hour Solutions Ltd., a subsidiary of High Roller Technologies, Inc. Corporate identities, registration numbers, and contact points are detailed below.

Legal Entity: Happy Hour Solutions Ltd. (Registration No. HE419393), Chytron, 3, Office 301, 1075 Nicosia, Cyprus
Parent Company: High Roller Technologies, Inc., 400 South 4th Street, Suite 500 - #390, Las Vegas, Nevada 89101, USA
Data Protection Contact: For privacy-related inquiries or data subject requests, email support@highrollers-nz.com. Attn: Data Protection Officer (DPO)
Licensing: Licensed by Estonian Tax and Customs Board (License Nos. HKL000374 & HKT000063, both active in 2025)

REFLECT: All privacy matters are managed in accordance with New Zealand's Privacy Act 2020, EU GDPR standards where applicable, and industry best practices.

What Personal Data We Collect

OBSERVE: Personal data is collected to facilitate your use of highrollers-nz.com, ensure regulatory compliance, and enhance service quality. The categories include:

Personal Identification Data: Full name, date of birth, nationality, address, email, phone number, account credentials
Technical Data: IP address, device identifiers, browser type, access logs, geolocation data
Payment Data: Credit/debit card details, bank account information, payment transaction history
Behavioral Data: Gambling/betting history, website interaction logs, preferences, time spent, clickstreams
Cookies & Tracking: Session and persistent cookies, analytics and advertising trackers, device fingerprinting technologies

EXPAND: Collection is both direct (user-provided) and indirect (automatic via website interaction and third-party tools).

Legal Basis for Processing

OBSERVE: Data processing is conducted under multiple lawful bases consistent with NZ Privacy Act 2020, GDPR, and gaming regulations:

User Consent: Obtained for account registration, marketing, cookies, and certain processing activities
Contract Fulfillment: Necessary for providing gaming services, processing payments, and managing your account
Legal Obligations: Compliance with KYC (Know Your Customer), AML (Anti-Money Laundering), responsible gambling, and regulatory reporting requirements
Legitimate Interests: Prevention of fraud, ensuring platform security, service analytics, and business improvement, balanced against user rights

REFLECT: We ensure processing is limited to purposes compatible with these legal grounds and maintain clear records of processing activities for compliance audits.

Purpose of Processing

OBSERVE: Your personal data is processed for the following purposes:

Service Provision: Creating and managing your account, facilitating deposits/withdrawals, delivering gambling services
Service Improvement: Monitoring usage, troubleshooting, and enhancing user experience based on analytics
Marketing Communications: Sending promotional material, newsletters, and tailored offers with your consent
Analytics: Aggregating behavioral data to understand trends and improve service delivery
Fraud Prevention & Security: Detecting suspicious activity, mitigating risks, and enforcing platform policies
Legal & Regulatory Compliance: Satisfying obligations under NZ and international gambling laws

REFLECT: All processing purposes are transparently communicated and strictly limited to original collection intent, with user rights respected at every stage.

Disclosure & Sharing

OBSERVE: We may disclose your data to third parties under controlled circumstances:

Payment Processors: To facilitate deposits, withdrawals, and verify payment sources
Service Providers: IT infrastructure, data analytics, cloud hosting, and marketing partners under contractual confidentiality
Regulators & Authorities: For fulfilling statutory requirements (Estonian, NZ, EU, and other relevant authorities)
Affiliates & Group Companies: Within High Roller Technologies group to administer services and comply with group policies
Advertising Networks (with Consent): For targeted advertising, only where you have agreed

EXPAND: All recipients are contractually obligated to protect your data and only use it for the intended purposes. No data is sold or shared for unrelated commercial purposes.

International Transfers

OBSERVE: Your personal data may be processed and stored outside New Zealand, including the European Union (Estonia, Cyprus) and the United States, to support global operations.

Data Transfer Mechanisms: Standard Contractual Clauses (SCCs) and equivalent safeguards are implemented for transfers outside the EEA
Third-Country Protections: Where local laws do not offer adequate protection, additional contractual and technical safeguards are applied
Transparency: Users are informed of international transfers and have access to relevant protective documentation upon request

REFLECT: We comply with NZ Privacy Act 2020, GDPR international transfer requirements, and all highrollers-nz.com operations are subject to robust security evaluations for cross-border data flows.

Regional Compliance Note: All transfers from NZ to the EU/EEA are justified by recognized international legal mechanisms as of 2025.

Data Retention

OBSERVE: highrollers-nz.com retains personal data only as long as necessary for the purposes for which it was collected, or as required by law:

Personal Identification & Account Data: Retained for the duration of account activity and up to 5 years following account closure (in line with AML, KYC, and regulatory obligations)
Payment & Transaction Records: Kept for a minimum of 7 years to satisfy statutory and audit requirements
Behavioral & Technical Data: Retained for up to 3 years for analytics, security, and dispute resolution purposes
Cookies & Tracking Data: Retention periods vary by type (see Cookies section)

EXPAND: Data may be deleted earlier upon user request if not required for legal or regulatory compliance. Data is securely erased or anonymized upon expiration of retention period.

Your Rights

OBSERVE: Under NZ Privacy Act 2020, EU GDPR, and (where relevant) Mexican data protection laws, you are entitled to:

Access: Obtain a copy of your personal data held by highrollers-nz.com
Correction: Request rectification of inaccurate or incomplete data
Deletion: Request erasure of personal data, subject to statutory retention obligations
Restriction: Request restriction of processing where legally justified
Objection: Object to processing for marketing or legitimate interests
Portability: Receive your data in a structured, commonly used, machine-readable format
Withdrawal of Consent: Withdraw consent for marketing or non-essential processing at any time

Procedures: To exercise your rights, contact our DPO at support@highrollers-nz.com. Requests are processed within 30 days, free of charge, unless manifestly unfounded or excessive. If you are dissatisfied with our response, you have the right to escalate to the NZ Privacy Commissioner or relevant EU/Mexican authority as applicable.

Cookies & Tracking Technologies

OBSERVE: highrollers-nz.com utilizes cookies and similar technologies to:

Session Cookies: Maintain secure user sessions and authentication
Persistent Cookies: Remember user preferences and improve login convenience
Third-Party Cookies: Provide analytics (e.g., Google Analytics), advertising, and social media integration

Management: You can manage or disable cookies via browser settings or the website's cookie management panel. Disabling cookies may affect site functionality.

REFLECT: Detailed information on cookies (including cookie list and purposes) is available in our Cookie Policy. We comply with NZ and EU standards for user consent and cookie transparency.

Data Security

OBSERVE: highrollers-nz.com implements industry-standard measures to safeguard your information:

Encryption: TLS 1.2+ for data in transit, strong encryption for data at rest
Access Controls: Multi-factor authentication, role-based access, and strict staff permissions
Security Audits: Regular internal and external reviews, penetration testing, and vulnerability assessments
Staff Training: Ongoing privacy and security training for all employees
Incident Response: Documented procedures for breach detection, response, and regulatory notification
Standards Compliance: Alignment with ISO 27001 and SOC 2 frameworks where applicable

REFLECT: While we employ advanced measures, no system is entirely immune to risk. Users are encouraged to maintain strong, unique passwords and safeguard their credentials.

Complaints & Contacts

OBSERVE: If you have concerns or wish to make a complaint regarding your personal data, you may:

Contact our Data Protection Officer via email: support@highrollers-nz.com
Use any feedback or complaint form provided within your user account (if available)
Send correspondence to: Happy Hour Solutions Ltd., Chytron, 3, Office 301, 1075 Nicosia, Cyprus

Procedure: We will acknowledge your complaint within 5 business days and aim to resolve all issues within 30 days. If you remain dissatisfied, you may escalate to:

NZ Privacy Commissioner: https://privacy.org.nz/, Phone: +64 4 474 7590
Estonian Data Protection Inspectorate: https://www.aki.ee/
EU Data Protection Authorities: See EDPB list

REFLECT: All complaints are investigated impartially and confidentially, with full compliance to statutory response timelines and escalation protocols.

Updates

OBSERVE: This Privacy Policy is reviewed and updated regularly to reflect regulatory changes, operational updates, and user feedback.

Notification: Users are notified of material changes by email, prominent website banners, and account dashboard alerts
Advance Notice: For significant changes, at least 30 days' advance notice is provided before new terms take effect
User Options: You may object to changes or close your account at any time without penalty
Version Control: Last updated: 6 November 2025
Changelog: Material modifications will be summarized at the start of each updated version

REFLECT: Continued use of highrollers-nz.com after notice of changes constitutes acceptance of the revised Privacy Policy. We encourage users to review this document regularly for updates.