Privacy Policy

This Privacy Policy explains how Cleopatra, available via the website https://cleopatra-aussie.com, collects, uses, discloses and protects personal information of website visitors and players who interact with our services. It applies to all users who access or use the site, whether or not they register an account with any third-party casino operators we review or link to. This Policy is effective from 1 January 2026 and supersedes all earlier versions.

Who We Are

OBSERVE: The site is an informational and affiliate review project focused on online gambling offerings, primarily associated with the "Cleopatra" brand operated by Dama N.V. under a Curaçao licence and targeted at Australian users in a grey/illegal market context.

EXPAND: For privacy compliance, we must clearly identify the entities involved in operating this review site and in handling user data, distinguishing between our informational role and the operational role of the gambling operator we describe.

REFLECT: We therefore define the following structure and contact points for data protection matters.

Website operator / controller for this site

• Project name: Cleopatra (the "Website", "we", "our", "us")
• Brand name referenced: Cleopatra (online gambling brand)
• Primary domain: https://cleopatra-aussie.com
• Primary purpose: Independent review and informational/affiliate site about Cleopatra and related online casino services. We do not operate real-money gambling; that is done by third-party operators.

Operator of Cleopatra casino services (third party)

• Company name: Dama N.V.
• Legal / registered address: Julianaplein 36, Willemstad, Curaçao
• Company registration number: 152125 (Curaçao commercial register)
• Gaming licence: 8048/JAZ2020-013 issued by Antillephone N.V., Curaçao (online gambling / interactive gaming services)
• Note: Dama N.V. and/or its related entities such as Strukin Ltd (Cyprus) may process your data separately as independent controllers when you register or play at Cleopatra or other casinos. Their own privacy policies apply in those situations.

Data protection contact for this Website

• Data Protection Contact / Department: Data Protection Desk - Cleopatra
• Email (primary): [email protected] (critically important and preferred for privacy requests)
• Email (general/legal): [email protected]
• Postal address for written complaints relating to this Website:
  Data Protection Desk - Cleopatra
  c/o Dama N.V., Julianaplein 36, Willemstad, Curaçao

If you interact directly with the Cleopatra casino or other Dama N.V. properties, you should also consult and, where appropriate, contact Dama N.V. or Strukin Ltd via the contact details provided in their own privacy policies.

What Personal Data We Collect

OBSERVE: Users of Cleopatra may browse content, subscribe to communications, or follow affiliate links to third-party casinos. In doing so, they generate a range of personal and technical data.

EXPAND: For compliance and transparency we categorise data by type and by source (you, your device, or partners) and distinguish between data processed on this Website and data processed by casinos we refer to.

REFLECT: Below we outline the main categories of data processed in connection with this Website; data processed by third-party operators is broadly similar but governed by their separate policies.

Identity and contact data

• Full name, display name or alias (if you submit inquiries, feedback or requests).
• Email address (e.g., when you contact us at [email protected] or subscribe to newsletters or alerts, where offered).
• Optional contact details such as phone number if you choose to provide them in correspondence.

Technical and usage data

• IP address and approximate geolocation (country/region) derived from your IP to tailor content (e.g., AU-focused information) and for security and anti-fraud.
• Device information: device type, operating system, browser type and version, language, screen resolution and similar technical parameters.
• Log data: access dates and times, pages viewed, referral URLs, clickstream data, error logs and similar diagnostic information.

Cookies and similar technologies

• HTTP cookies, pixels, tags, SDKs and local storage elements used to:
  • Remember your preferences (language, cookie choices, content settings).
  • Measure traffic and usage patterns (analytics cookies).
  • Attribute affiliate commissions when you follow our outbound links to third-party casinos or advertisers (tracking cookies).

Marketing and communication data

• Your marketing preferences (opt-in/opt-out to receive promotional emails or alerts about Cleopatra or related offers, where such services are provided).
• Records of our communications with you (e.g., support interactions, responses to surveys or feedback forms if implemented).

Behavioural and interaction data (on this Website)

• Click behaviour on Cleopatra (e.g., which reviews, articles, links or banners you view or click).
• Engagement metrics such as time on page, scroll depth and interactions with specific content blocks (through analytics tools).

Data processed by third-party gambling operators

• When you register or play at Cleopatra casino or other sites operated by Dama N.V. or partners, they may collect:
  • Full legal name, date of birth, residential address, nationality.
  • Government-issued ID, proof of address and KYC/AML verification data.
  • Payment information (card details, e-wallet IDs, bank account details, transaction history).
  • Betting, gaming and transaction history, deposit and withdrawal records, bonuses used, self-exclusion and limits.
• Such processing is carried out under their own capacity as controllers, subject to their privacy policies and licensing requirements in Curaçao and other jurisdictions.

Legal Basis for Processing

OBSERVE: Our processing must rely on valid legal grounds under applicable data protection principles (including EU-style and international standards), even though Cleopatra is focused on Australian users and operated from Curaçao.

EXPAND: Because our audience and infrastructure may be cross-border, we align our legal bases with generally recognised frameworks (e.g., GDPR-style categories), and apply them to each purpose.

REFLECT: We therefore process personal information on the following bases:

• Consent
  • We rely on your explicit consent for:
    • Sending you marketing communications (newsletters, promotional emails) about Cleopatra or related offers.
    • Using non-essential cookies and similar technologies for analytics and advertising, where a consent banner or settings tool is presented.
  • You may withdraw consent at any time (see "Your Rights").
• Performance of (or steps to enter into) a contract
  • Where we provide you with user-initiated services, such as:
    • Responding to your inquiries and support requests.
    • Providing subscription-based alerts or personalised content, where available.
  • In relation to any affiliate or partnership arrangements, we process technical and referral data necessary to operate and attribute such services.
• Legitimate interests
  • We may process data where necessary for our legitimate business interests, provided these are not overridden by your rights, including:
    • Operating, securing and improving Cleopatra and its content.
    • Preventing fraud, abuse, unauthorised access, bot traffic or other harmful activity.
    • Analysing aggregated usage patterns to improve user experience and site performance.
    • Protecting and exercising our legal rights and defending against claims.
• Compliance with legal obligations
  • We may be required to retain and disclose certain information to:
    • Comply with applicable laws in Curaçao and other relevant jurisdictions.
    • Assist law enforcement, regulatory bodies, tax or anti-money laundering authorities where we are legally compelled to do so.

Regional compliance note: In Australia, interactive gambling services offered to residents without a local licence are generally prohibited and subject to enforcement by the Australian Communications and Media Authority (ACMA). Cleopatra is an informational/affiliate site and does not itself provide gambling services or hold an Australian gambling licence. Any personal data processing linked to actual gambling activity is primarily carried out by offshore operators such as Dama N.V. under Curaçao law and their own privacy frameworks.

Purpose of Processing

OBSERVE: Users need clarity on why their personal and technical data are processed.

EXPAND: Our purposes span content delivery, analytics, marketing, security and regulatory cooperation, particularly in a sensitive sector like online gambling and a grey/illegal market context for Australians.

REFLECT: We therefore group purposes as follows:

• Providing and operating the Website
  • Delivering content, reviews and comparison information about Cleopatra and related gambling services.
  • Ensuring the Website functions correctly across devices and browsers.
  • Handling your requests, questions or complaints sent to [email protected] or [email protected].
• Personalisation and service improvement
  • Tailoring content (for example, showing AU-relevant information) based on your approximate location and prior interactions.
  • Conducting analytics to understand how users interact with Cleopatra, which sections are popular, and where improvements are needed.
• Marketing and communications
  • Sending you newsletters or promotional messages regarding Cleopatra or related offers if you have given consent.
  • Measuring the performance of campaigns and affiliate links (e.g., whether a user who clicked an outbound link registered or converted at a partner site, without receiving full payment details).
• Affiliate and partnership management
  • Using tracking identifiers and referral information to attribute traffic and conversions to Cleopatra for commission and reporting purposes.
• Security, fraud prevention and legal protection
  • Detecting and mitigating malicious activity (spam, DDoS attacks, unauthorised scraping, misuse of affiliate links).
  • Keeping records necessary to prevent fraud and to respond to legal or regulatory requests.
• Compliance and risk management
  • Maintaining records and logs that demonstrate compliance with data protection and other applicable laws.
  • Cooperating, where required, with regulators such as ACMA or other supervisory bodies.

Disclosure & Sharing

OBSERVE: Personal data related to Cleopatra may be shared with several categories of recipients.

EXPAND: Given the cross-border and affiliate nature of operations, sharing includes technical service providers, payment and affiliate partners, and regulatory agencies, including circumstances where Australians access offshore gambling services.

REFLECT: We limit sharing to what is necessary, apply appropriate safeguards, and do not sell your personal information as a standalone asset.

• Technical and hosting service providers
  • Hosting companies, content delivery networks (CDNs), DDoS mitigation providers and IT support companies that enable the operation, security and maintenance of Cleopatra.
• Analytics and measurement providers
  • Third-party analytics platforms that help us understand Website usage patterns and performance. Where possible, data is aggregated or pseudonymised.
• Affiliate, advertising and marketing partners
  • Affiliate networks and advertising partners that work with us to promote Cleopatra and related brands. We may share:
    • Technical identifiers (e.g., cookie IDs, click IDs).
    • Non-directly identifiable conversion information necessary for commission attribution.
  • We share data for targeted advertising only where permitted by law and, where required, based on your consent to marketing cookies.
• Third-party casino operators
  • When you click through to or create an account with Cleopatra casino or other Dama N.V. properties via our links, we may exchange limited tracking information with those operators to confirm that a registration or transaction is attributable to Cleopatra.
  • Those operators act as independent controllers of the personal and financial data you provide directly to them (identity documents, payment data, gaming data). Their privacy policies govern such processing.
• Regulators, authorities and dispute bodies
  • Where required by law, we may disclose information to:
    • Regulators in Curaçao (e.g., the licensing authority for Dama N.V.).
    • Regulatory or enforcement agencies in other jurisdictions, including ACMA in Australia, in response to lawful requests.
• Professional advisers and corporate transactions
  • Lawyers, auditors, consultants and insurers who assist with legal, compliance or risk management.
  • Potential buyers or investors and their advisers in connection with any proposed merger, acquisition or restructuring, subject to confidentiality obligations.

International Transfers

OBSERVE: Cleopatra targets users in Australia but is operated from Curaçao and relies on global service providers.

EXPAND: This necessarily involves cross-border transfers of personal data, including to countries that may not provide the same level of data protection as your home jurisdiction (e.g., the EU, Australia).

REFLECT: We therefore use contractual and technical safeguards that are consistent with widely recognised standards.

• Locations of processing
  • Primary operational jurisdiction: Curaçao (Dama N.V. registered address at Julianaplein 36, Willemstad, Curaçao).
  • Additional jurisdictions: data may be processed or stored on servers located in the European Union, the United Kingdom, the United States, Australia or other countries where our hosting, analytics and affiliate partners are based.
• Safeguards for international transfers
  • Where required by applicable law, we use:
    • Standard Contractual Clauses (SCCs) or equivalent contractual mechanisms when transferring data from the EEA/UK to countries without an adequacy decision.
    • Contractual data protection obligations in agreements with processors and partners, including confidentiality, data security and restricted use of data solely for specified purposes.
  • We also implement technical safeguards such as encryption in transit and at rest and access controls, as described in "Data Security".
• Note for Australian users
  • By using Cleopatra and, where applicable, by following our links to offshore gambling services, you acknowledge that your data may be transferred to and processed in jurisdictions (including Curaçao and others) that may have different privacy and data protection regimes to Australia.

Data Retention

OBSERVE: Data must not be kept longer than necessary for the purposes for which it was collected.

EXPAND: Our retention practices must account for legal obligations (e.g., financial record-keeping), security and dispute-resolution needs in a high-risk sector such as gambling-related services, even though our role is informational/affiliate.

REFLECT: We therefore apply differentiated retention periods and clear deletion criteria.

• General principle
  • We retain personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, including satisfying any legal, accounting or reporting requirements, and then either delete or irreversibly anonymise it.
• Specific retention periods (indicative)
  • Contact and inquiry data: up to 3 years after our last meaningful interaction with you, to allow follow-up and to manage potential disputes.
  • Marketing data (email subscriptions, consent logs): for as long as you remain subscribed and for up to 2 years thereafter to demonstrate compliance with consent requirements.
  • Technical logs and security data: typically 6 - 24 months, depending on the type of logs, to support troubleshooting, security investigations and regulatory enquiries.
  • Affiliate tracking and attribution data: up to 5 years from the relevant transaction or event, to comply with contractual and financial record-keeping requirements.
• Third-party casino data
  • Data you provide directly to Cleopatra casino or other Dama N.V. properties (e.g., identity documents, payment records, gaming history) is retained by those operators in line with their own policies and legal obligations (such as KYC/AML rules) and may extend beyond the periods described above.
• Deletion and anonymisation
  • When data is no longer required, we will:
    • Securely delete or overwrite it; or
    • Aggregate and/or anonymise it so that it can no longer be linked to an identifiable individual (e.g., for statistical reports).
  • Your right to request deletion is described under "Your Rights". In some cases we may retain limited data where legally required or where necessary to establish, exercise or defend legal claims.

Your Rights

OBSERVE: Users should be able to understand and exercise privacy rights resembling those under modern data protection regimes (such as the EU GDPR and other comprehensive laws).

EXPAND: Although Cleopatra is aimed at Australian users and operated from Curaçao, we align our practices with widely recognised standards, including rights of access, rectification, erasure, restriction, objection, portability and consent withdrawal.

REFLECT: We therefore voluntarily offer the following rights in relation to data we control for this Website (noting that separate rules may apply at third-party casinos):

• Right of access
  • You may request confirmation of whether we process personal data about you and, if so, receive a copy of that data and associated information (e.g., purposes, categories, recipients, retention periods).
• Right to rectification
  • You may request that we correct or complete inaccurate or incomplete personal data we hold about you (for example, if your contact details change).
• Right to erasure ("right to be forgotten")
  • You may request deletion of your personal data where:
    • It is no longer necessary for the purposes for which it was collected; or
    • You withdraw consent and there is no other legal basis for processing; or
    • You have successfully objected to processing; or
    • The data has been unlawfully processed.
  • We may still retain certain data where required by law or for the establishment, exercise or defence of legal claims.
• Right to restriction of processing
  • You may request that we restrict processing of your data in certain circumstances, such as:
    • When you contest the accuracy of the data (for a period enabling us to verify it); or
    • When processing is unlawful but you oppose erasure; or
    • When we no longer need the data but you require it for legal claims.
• Right to object
  • You may object at any time to processing based on our legitimate interests, including profiling on that basis. We will stop processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms or where processing is required for legal claims.
  • You have an absolute right to object at any time to processing of your personal data for direct marketing purposes, after which we will stop such marketing.
• Right to data portability
  • Where technically feasible and applicable, you may request that we provide you with personal data you have provided to us in a structured, commonly used and machine-readable format, or transmit it to another controller.
• Right to withdraw consent
  • Where processing is based on your consent (e.g., marketing emails, non-essential cookies), you may withdraw that consent at any time. This will not affect the lawfulness of processing carried out before withdrawal but we will cease processing based on that consent going forward.

How to exercise your rights

• Submit your request by emailing [email protected] or, alternatively, [email protected].
• Please provide:
  • Your full name and contact email.
  • A clear description of the right you wish to exercise and, where relevant, any specific data or interactions concerned.
  • Any additional information that may help us locate your data (e.g., approximate dates of interaction).
• For security, we may need to verify your identity (for example, by confirming control of your email address or asking limited additional questions). We will not request more data than necessary for verification.

Response timeframes and cost

• We aim to respond to all valid requests within 30 days of receipt.
• Where your request is particularly complex or numerous, we may extend this period by a further 30 days and will inform you of the extension and reasons.
• We will handle requests free of charge. However, we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded or excessive, in line with recognised international standards.

Note: To exercise rights relating to data processed by Cleopatra casino or other Dama N.V. properties (e.g., your betting history, KYC records), you must contact those operators directly using the details in their own privacy notices.

Cookies & Tracking Technologies

OBSERVE: The Website uses cookies and similar technologies for functionality, analytics, affiliate tracking and, where permitted, advertising.

EXPAND: Cookies can affect privacy, especially when used for cross-site tracking and profiling, so users must be able to understand their types and control them.

REFLECT: We categorise our use of cookies and provide management options as follows.

Types of cookies we use

• Session cookies
  • Temporary cookies that exist only while your browser is open and are deleted when you close it. They help the site function correctly during your visit (e.g., managing navigation, remembering short-term preferences).
• Persistent cookies
  • Cookies that remain on your device for a defined period or until you delete them. They may store preferences (such as language or cookie choices) and help us recognise returning visitors.
• First-party cookies
  • Cookies set by Cleopatra (under the cleopatra-aussie.com domain) for functionality, security and basic analytics.
• Third-party cookies
  • Cookies set by external services integrated with our site, such as analytics providers, affiliate networks and advertising partners. These may track your activity across multiple websites, depending on your settings and consent.

Purposes of cookies

• Strictly necessary / functional cookies
  • Required for the Website to operate and for you to navigate and use its features (e.g., remembering cookie consent decisions).
• Analytics / performance cookies
  • Help us understand how visitors use the site, which pages are most popular, how users move around the site and if they encounter errors.
• Affiliate and advertising cookies
  • Used to track clicks from Cleopatra to third-party casino operators and to measure conversions for commission and campaign performance.
  • Where advertising or remarketing is used, these cookies may help deliver more relevant ads on other sites, subject to applicable legal requirements and your consent.

Managing and disabling cookies

• You can manage cookies through:
  • Browser settings: Most browsers allow you to block or delete cookies, or to alert you before a cookie is stored. The procedure varies by browser (e.g., Chrome, Firefox, Safari, Edge).
  • Cookie banners or settings tools: Where implemented, you may use our on-site cookie management interface to accept or reject non-essential cookies.
• Disabling some cookies may affect the functionality or performance of the Website and may limit your ability to use certain features.

Data Security

OBSERVE: The processing of data related to gambling-associated services is inherently sensitive, particularly in a jurisdiction (Australia) where offshore interactive gambling is restricted.

EXPAND: We are required and motivated to apply strong technical and organisational measures to protect personal and technical data against unauthorised access, loss or misuse, aligning with generally recognised information security standards.

REFLECT: While we do not claim formal certification such as ISO 27001 or SOC 2 unless explicitly obtained, we adopt controls consistent with such frameworks.

• Encryption
  • Data in transit between your browser and cleopatra-aussie.com is protected using industry-standard TLS (Transport Layer Security) version 1.2 or higher, where supported by your browser.
  • Where feasible, we also use encryption or other forms of pseudonymisation for data at rest on our servers or those of our service providers.
• Access controls
  • Access to personal data is restricted to authorised personnel or service providers who need it for legitimate purposes (e.g., support, maintenance, analytics).
  • User permissions follow the principle of least privilege and are regularly reviewed.
• Authentication and account security (if/where accounts exist)
  • Where the Website offers user accounts or dashboards, we encourage the use of strong, unique passwords and, where available, multi-factor authentication (MFA).
• Operational security and training
  • Internal staff and contractors with access to data are bound by confidentiality obligations and receive guidance on data protection and security best practices.
• Monitoring, testing and audits
  • We monitor systems for suspicious activity and potential vulnerabilities and work with our hosting and security partners to implement timely updates and patches.
  • We conduct periodic security reviews of our infrastructure and key third-party providers.
• Incident response
  • We maintain procedures for responding to suspected personal data breaches, including:
    • Prompt investigation and containment.
    • Assessment of the likely impact on users.
    • Notification to affected individuals and relevant authorities where required by applicable law.

While we strive to protect your data using commercially reasonable safeguards, no system can be guaranteed to be 100% secure. You should therefore also take care to protect your devices and credentials and to avoid sharing sensitive information via unsecured channels.

Complaints & Contacts

OBSERVE: Users require clear channels to raise questions or complaints regarding privacy and data protection.

EXPAND: Although this site is oriented toward Australian users and operated from Curaçao, complaints may engage multiple authorities depending on where users, infrastructure and partners are located.

REFLECT: We therefore establish a structured complaint procedure, along with information about escalating matters to supervisory authorities where applicable.

Contacting us about privacy

• Primary contact for privacy matters:
  • Email: [email protected]
• Alternative/general contact:
  • Email: [email protected]
• Postal address:
  • Data Protection Desk - Cleopatra
    c/o Dama N.V.
    Julianaplein 36, Willemstad, Curaçao

Internal complaint procedure

1. Submission: Send a detailed description of your concern or complaint to [email protected], including:
   • Your name and contact information.
   • A clear statement of the issue, the data or processing involved, and relevant dates.
   • Any supporting documentation (such as screenshots or correspondence).
2. Acknowledgement: We will acknowledge receipt of your complaint within 7 business days, where possible.
3. Investigation: We will investigate your complaint internally, which may include liaising with relevant service providers or partner operators where necessary.
4. Response: We aim to provide a substantive response or resolution within 30 days of receipt. If we require more time (for example, due to complexity or involvement of third parties), we will notify you of the delay and our expected timeframe.
5. Escalation: If you are not satisfied with our response, you may request that your complaint be escalated internally for further review.

Escalation to supervisory authorities

Depending on your location and the circumstances, you may also have the right to lodge a complaint with a data protection or regulatory authority in your country of residence or where you consider that your rights have been infringed.

• Australia - Online gambling complaints and information
  • Authority: Australian Communications and Media Authority (ACMA)
  • Website: https://www.acma.gov.au/online-gambling-services
  • Note: ACMA focuses on enforcement against prohibited online gambling services and consumer risks, rather than acting as a general privacy regulator for offshore sites. However, you may consult ACMA's resources for guidance on dealing with unlicensed offshore gambling providers.
• Other jurisdictions
  • If you are located in the European Union, United Kingdom or another jurisdiction with a dedicated data protection authority, you may have the right to complain to that authority. Please consult the website of your local regulator for contact details and procedures.

We encourage you to contact us first so we can attempt to resolve your concerns directly, but you are not required to do so before approaching an authority, where applicable law provides you with a direct right of complaint.

Updates

OBSERVE: Privacy laws, regulatory expectations (including ACMA guidance regarding offshore gambling) and our own practices may evolve over time.

EXPAND: We must transparently inform users about changes to this Policy, especially when they materially affect how we collect or use data, or when they relate to new services or jurisdictions.

REFLECT: We therefore maintain version control and provide advance notice for significant changes where feasible.

• Versioning and "Last updated" date
  • This Privacy Policy is currently version 4.0.
  • Last updated: January 2026.
• Notification of changes
  • We may update this Policy from time to time. When we make material changes, we will:
    • Post the updated Policy on https://cleopatra-aussie.com with a new "Last updated" date; and
    • Where appropriate, provide additional notice, such as:
      • A banner or pop-up notification on the Website;
      • An email notification to subscribed users; or
      • A notice within any user account or dashboard, if such features are provided.
• Advance notice for significant changes
  • For changes that materially affect your rights or how we process your personal data (for example, introducing new categories of data or new types of recipients), we will, where reasonably practicable, provide at least 30 days' advance notice before the changes take effect.
  • During this notice period, you may object to the changes or stop using the Website if you do not agree with them. If processing is based on consent, you may withdraw your consent at any time.
• Changelog of material changes
  • We will keep a brief record of material amendments, such as:
    • Expanded description of international transfers and safeguards.
    • Clarified relationship between Cleopatra and Dama N.V. as an offshore gambling operator licensed in Curaçao.
    • Updated contact details and complaint procedures, including reference to ACMA guidance as of 2026.

Continued use of Cleopatra after the effective date of an updated Privacy Policy will constitute your acknowledgment of the changes. Where required by law, we will seek your consent to material changes that affect how we process your personal data.