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Privacy Policy

1. Introduction

This Privacy Policy describes how Carletta N.V. ("we," "us," or "the platform") collects, uses, stores, and protects personal data of users of Pin-Up. By using our services, you consent to the practices described in this policy.

Data Controller: Carletta N.V., registration number 142346, Dr. Henri Fergusonweg 1, Curacao.

2. Data We Collect

Account Registration Data:

  • Full name, date of birth, gender
  • Email address, phone number
  • Country of residence
  • Preferred currency and language

Verification Data (KYC):

  • Government-issued ID (passport or NID) — image
  • Proof of address (utility bill or bank statement) — if requested
  • Payment method verification — if requested

Transaction Data:

  • Deposit and withdrawal history
  • Payment method details (bKash number, card last 4 digits)
  • Transaction amounts and timestamps

Usage Data:

  • Games played, bet amounts, session duration
  • Device type, operating system, browser
  • IP address, approximate location
  • Pages visited, features used

Communications:

  • Live chat transcripts
  • Email correspondence
  • Support tickets

3. How We Use Your Data

  • Account Management: Creating, maintaining, and verifying your account
  • Transaction Processing: Processing deposits, withdrawals, and bonus credits
  • Legal Compliance: Meeting KYC/AML requirements under Curacao gaming regulations
  • Security: Detecting and preventing fraud, unauthorized access, and abuse
  • Service Improvement: Analyzing usage patterns to improve platform features
  • Communications: Sending account notifications, promotional offers (with consent), and support responses

4. Legal Basis for Processing

  • Contractual necessity: To provide our services as agreed in the Terms and Conditions
  • Legal obligation: To comply with Curacao gaming regulations, KYC/AML requirements
  • Legitimate interest: To maintain platform security, prevent fraud, and improve services
  • Consent: For marketing communications (which you can withdraw at any time)

5. Data Sharing

We may share your data with:

  • Payment Processors: bKash, Nagad, Rocket, Visa, Mastercard — to process transactions
  • Payment Agents: B.W.I Black-Wood Limited and Carletta Limited (Cyprus) — as payment agents of Carletta N.V.
  • Software Providers: Game providers may receive anonymized gameplay data for RNG auditing
  • Regulatory Authorities: The Curacao Gaming Control Board — upon request for regulatory compliance
  • Legal Requirements: Law enforcement or judicial authorities — when required by law

We do not sell personal data to third parties for marketing purposes.

6. Data Security

  • SSL 256-bit encryption on all data transmissions
  • Encrypted storage for sensitive personal and financial data
  • Access controls limiting employee access on a need-to-know basis
  • Regular security audits of systems and processes
  • Two-Factor Authentication (2FA) available for all user accounts

7. Data Retention

  • Active accounts: Data retained for the duration of account activity
  • Closed accounts: Data retained for minimum 5 years per Curacao regulations
  • Transaction records: Retained for minimum 5 years per regulatory requirements
  • Marketing data: Retained until you withdraw consent

8. Your Rights

You have the right to:

  • Access your personal data held by us
  • Correct inaccurate or incomplete data
  • Delete your data (subject to legal retention requirements)
  • Restrict processing in certain circumstances
  • Object to processing for marketing purposes
  • Withdraw consent for marketing communications at any time

To exercise any of these rights, contact us at [email protected] or via live chat.

9. Cookies

The platform uses cookies for:

  • Essential cookies: Session management, authentication, security
  • Functional cookies: Language preferences, display settings
  • Analytics cookies: Understanding usage patterns to improve the platform

You can manage cookie preferences through your browser settings. Disabling essential cookies may affect platform functionality.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Significant changes will be communicated via email or on-site notification. Continued use of the platform after changes constitutes acceptance.

11. Contact

For privacy-related inquiries:

  • Email: [email protected]
  • Live Chat: Available 24/7
  • Address: Carletta N.V., Dr. Henri Fergusonweg 1, Curacao

Last updated: March 2026