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Privacy Policy

This Privacy Policy outlines how twin-casino collects, uses, stores, and protects personal information derived from your use of the website twin-nz.com. This document applies to all registered players and visitors accessing our services from New Zealand. It details our commitment to data protection effective as of November 6, 2025.

Who We Are

The data controller responsible for your personal information on twin-nz.com is Oring Ltd., a limited liability company incorporated under the laws of Malta. We are committed to upholding global data protection standards in our operations serving the New Zealand market.

Key Corporate Details:

  • Legal Entity: Oring Ltd. (founded 2017)
  • Headquarters: Malta
  • Operational Domain: twin-nz.com

We have appointed a dedicated team to oversee data protection compliance. While our primary operations are based in Malta, we ensure full alignment with local requirements for our New Zealand clientele. For specific privacy-related inquiries, please refer to the "Complaints & Contacts" section below.

What Personal Data We Collect

To provide a secure and legally compliant gambling environment on twin-nz.com, we must collect specific categories of data. This collection is necessary for account management, fraud prevention, and adherence to New Zealand's anti-money laundering (AML) regulations.

Categories of Data Processed

  • Identity Data: This includes your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender. We also require government-issued identification (such as a Passport or Driver's License) for age verification.
  • Contact Data: Your billing address, residential address, email address, and telephone numbers.
  • Financial & Transaction Data: Details regarding your bank account, payment card details (encrypted), and the history of deposits and withdrawals made in New Zealand Dollars (NZD).
  • Technical Data: Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and platform used to access twin-nz.com.
  • Usage & Betting Data: Information about how you use our website, games, and services, including wagering history, game session durations, and bonuses claimed.
  • AML Compliance Data: Information regarding Source of Wealth (SoW) and Source of Funds (SoF) as required by the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (NZ).

Legal Basis for Processing

We process your personal data only when we have a lawful basis to do so. Our processing activities are grounded in the following legal frameworks, ensuring alignment with both the New Zealand Privacy Act 2020 and international standards (GDPR):

  • Performance of a Contract: Processing is necessary to create your account, process your NZD transactions, and enable gameplay on twin-nz.com. Without this data, we cannot provide our services to you.
  • Legal Obligation: We are required by law to process data for age verification, responsible gambling checks, and anti-money laundering (AML) reporting.
  • Legitimate Interests: We process data to detect and prevent fraud, maintain network security, and analyze customer behavior to improve our services, provided these interests do not override your fundamental rights.
  • Consent: For specific activities, such as direct marketing communications or the use of non-essential tracking cookies, we rely on your explicit consent, which you may withdraw at any time.

Purpose of Processing

We utilize your data for specific, defined purposes related to the operation of twin-casino services:

  • To register you as a new customer and verify your identity.
  • To process deposits and withdrawals via our payment partners.
  • To manage our relationship with you, including notifying you of changes to our terms or privacy policy.
  • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
  • To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences.

Disclosure & Sharing

Your personal data is treated with strict confidentiality. However, to operate twin-nz.com effectively, we may disclose data to the following third parties:

  • Service Providers: Third-party companies that provide IT and system administration services, game software providers (to launch game sessions), and customer support tools.
  • Payment Processors: Financial institutions facilitating NZD transactions.
  • Regulatory Bodies & Law Enforcement: We may share data with New Zealand authorities, the Malta Gaming Authority (where applicable for historical data), or other law enforcement agencies if required to comply with legal obligations or facilitate criminal investigations.
  • Professional Advisers: Lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
  • Affiliates & Advertising Networks: With your consent, we may share pseudonymized data with marketing partners to provide relevant offers.

International Transfers

As twin-casino is operated by Oring Ltd. (headquartered in Malta), your personal data collected in New Zealand will be transferred to and stored at destinations within the European Economic Area (EEA).

Protective Measures for Cross-Border Data:

  1. Adequacy Decisions: New Zealand is recognized by the European Commission as providing an adequate level of data protection, facilitating smooth data flows.
  2. Standard Contractual Clauses (SCCs): Where we transfer data to service providers outside the EEA or NZ that do not have an adequacy decision, we implement standard contractual clauses approved by the European Commission to ensure your data receives the same protection it has in New Zealand.
  3. Security Standards: All international transfers are encrypted and conducted over secure channels.

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

  • Active Accounts: Data is retained for the duration of your relationship with us.
  • Closed Accounts: Upon account closure, we are legally required (under AML regulations) to retain basic personal data, transaction history, and verification documents for a minimum period of five (5) years.
  • Deletion Criteria: Once the retention period expires, or if the purpose for processing ceases (and no legal obligation compels us to keep it), your data is securely deleted or anonymized so that it can no longer be associated with you.

Your Rights

Under the New Zealand Privacy Act 2020 and aligned with GDPR standards, you possess significant rights regarding your personal data. We are committed to facilitating these rights efficiently.

  • Right to Access: You have the right to request a copy of the personal data we hold about you (Information Privacy Principle 6).
  • Right to Correction: You may request correction of any data you believe is inaccurate or incomplete (Information Privacy Principle 7).
  • Right to Erasure ("Right to be Forgotten"): You may ask us to delete your personal data where there is no good reason for us to continue processing it, subject to our legal retention obligations (e.g., AML laws).
  • Right to Restriction of Processing: You can ask us to suspend the processing of your personal data in certain scenarios, such as while we verify the accuracy of the data.
  • Right to Withdraw Consent: Where we rely on consent to process your data (e.g., marketing), you may withdraw this consent at any time via your account settings or the "unsubscribe" link in emails.

Exercising Your Rights: To exercise any of these rights, please contact us. We generally respond to all legitimate requests within 30 days. This service is free of charge, though we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

Cookies & Tracking Technologies

twin-nz.com uses cookies to distinguish you from other users, helping us provide a good experience when you browse our website and allowing us to improve our site.

  • Strictly Necessary Cookies: Essential for the operation of the website (e.g., allowing you to log in and access secure areas).
  • Analytical/Performance Cookies: Allow us to recognize and count the number of visitors and see how visitors move around our website.
  • Functionality Cookies: Used to recognize you when you return to our website, enabling personalization of content (e.g., language or region choice).
  • Targeting Cookies: Record your visit to our website, the pages you have visited, and the links you have followed to make advertising more relevant to your interests.

You can manage your cookie preferences through your browser settings or our onsite cookie management tool. Please note that blocking necessary cookies may impact the functionality of the casino.

Data Security

We have implemented robust security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way.

Our Security Protocol Includes:

  • Encryption: All data exchanges on twin-nz.com are encrypted using TLS 1.2+ (Transport Layer Security) technology.
  • Access Control: Access to your personal data is limited to those employees, agents, contractors, and other third parties who have a business need to know. They are subject to a duty of confidentiality.
  • Testing & Audits: We regularly test our systems and carry out security audits. We also hold eCOGRA certification, confirming our adherence to high operational standards.
  • Incident Response: We have procedures to deal with any suspected personal data breach and will notify you and the relevant regulator of a breach where we are legally required to do so.

Complaints & Contacts

If you have any concerns about how we handle your data, or if you wish to exercise your rights, please contact our data protection team.

  • Data Protection Contact: Hamish Mitchell (via Customer Support)
  • Email: Support is available via our general support email (please refer to the website footer for the current address).
  • Live Chat: Available 24/7 for registered users on twin-nz.com.
  • Online Form: Accessible via the "Contact Us" page.

External Escalation:

If you feel your data privacy rights have not been respected, you have the right to lodge a complaint with the Office of the Privacy Commissioner (New Zealand) via privacy.org.nz. Additionally, for gaming-related disputes involving data, you may contact our Alternative Dispute Resolution (ADR) provider, eCOGRA.

Updates

We keep our Privacy Policy under regular review. This version was last updated on November 6, 2025.

We may update this policy from time to time to reflect changes in law or our privacy practices. If we make material changes, we will notify you by email or by means of a prominent notice on twin-nz.com prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.