PRIVACY POLICY

Cosmic Strike Ltd, a company registered in England and Wales (Company No. 15621027), registered office 11-12 Tokenhouse Yard, London EC2R 7AS, United Kingdom, is the controller responsible for the personal information collected through cosmicwheelplay.com and the games available on it. The person accountable for our compliance with this policy is Derek Anderson, reachable at cosmicstrike@mailfence.com.

Because we are established in the United Kingdom, our processing is subject to the UK General Data Protection Regulation and the Data Protection Act 2018. Because we offer the Games to users in Australia, we also comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Where the two regimes differ, we apply the standard more protective of you.

This policy explains what personal information we collect, why we collect it, what our legal basis is, who we share it with, how long we keep it, and the choices and rights you have. It applies to the website, all games available on it, and our marketing.

• Account information: email address, username, password (stored only as a cryptographic hash), age confirmation, and the date your account was created.
• Game Development project inquiries: your name or representative name, business email address, company or brand identity, project requirements and specifications, desired mechanics and theme details, timeline preferences, and transmission metadata submitted via our custom game request form.
• Gameplay information: virtual coin balance, which games you play and for how long, spins, bonuses granted, and your in-game settings.
• Technical information: IP address, approximate location derived from it (country and state, not precise location), browser and device type, operating system, language, and referring page.
• Cookies and similar technologies: identifiers used to keep you signed in, to remember your age confirmation, and to measure traffic and advertising performance. See section 8.
• Support & Developer correspondence: messages you send us and our replies.

We do not collect payment card details, because the Games are free and we do not process payments. We do not collect sensitive information within the meaning of the Privacy Act, and we do not knowingly collect information from anyone under 18. You may use the Site without telling us your real name; where it is lawful and practicable, you may deal with us anonymously or under a pseudonym for general enquiries.

• To create and operate your account and save your progress — necessary for the performance of our contract with you (UK GDPR Art. 6(1)(b)).
• To review game development inquiries, prepare tailored technical proposals, and conduct business correspondence — taking pre-contractual steps at your request and our legitimate interest in commercial operations (Art. 6(1)(b) and (f)).
• To grant the 2,000-coin welcome bonus and other bonuses, and to detect duplicate accounts and bonus abuse — performance of our contract and our legitimate interest in preventing abuse (Art. 6(1)(b) and (f)).
• To confirm that users meet the minimum age requirement — our legitimate interest in operating an adults-only service and compliance with advertising rules (Art. 6(1)(f) and (c)).
• To keep the Site secure, prevent fraud, spam, and automated abuse, and investigate breaches of our Terms — our legitimate interest in the security of the Site (Art. 6(1)(f)).
• To provide customer and developer support — performance of our contract (Art. 6(1)(b)).
• To understand how the Site and the Games are used and improve them — your consent for analytics cookies, and otherwise our legitimate interest in aggregated statistics (Art. 6(1)(a) and (f)).
• To measure and optimise our communications and advertising campaigns — your consent (Art. 6(1)(a)).
• To comply with legal obligations and respond to lawful requests — compliance with a legal obligation (Art. 6(1)(c)).

We collect personal information only where it is reasonably necessary for these functions, and we do not use or disclose it for an unrelated purpose without your consent, unless an exception under the Privacy Act applies.

We send promotional messages only where you have agreed to receive them. Every message identifies us and contains a working unsubscribe link that we action promptly, as the Spam Act 2003 (Cth) requires. You can also turn promotional messages off in Settings or by writing to cosmicstrike@mailfence.com. Service messages about your account are not marketing and continue while your account is open.

We do not sell your personal information. We share it only with processors acting on our behalf, under contract and only for the purposes described above:

• hosting and infrastructure providers;
• game content providers, where licensed content is delivered from their systems;
• analytics providers, to measure use of the Site and the Games;
• advertising platforms, including Google, to measure and optimise our campaigns;
• email delivery providers, for account and service messages;
• professional advisers, and law enforcement or regulators where required by law.

Our commercial partners referred to in the Affiliate Disclosure do not receive your personal information from us.

We are based in the United Kingdom, and personal information about our Australian users is stored and processed outside Australia. The countries in which our providers are likely to hold your information are the United Kingdom, the United States, and countries in the European Economic Area. Before disclosing personal information overseas we take reasonable steps to ensure the recipient handles it in a way consistent with the Australian Privacy Principles, including contractual commitments, and for transfers out of the United Kingdom we rely on UK adequacy regulations or the International Data Transfer Agreement. While information is held in another country it may be accessible to the courts, law enforcement, and national security authorities of that country under its laws. You can ask us at cosmicstrike@mailfence.com where your information is held.

We use strictly necessary cookies to keep you signed in and to remember your age confirmation; the Site does not work without them. Analytics and advertising cookies are optional and are set only after you allow them through our cookie banner. You can change or withdraw your choice at any time through the cookie settings on the site, and you can block or delete cookies in your browser.

We keep account and gameplay information for as long as your account is open. After you close your account, or after 36 months of inactivity, we delete or de-identify it, except where we must keep specific records longer to comply with a legal obligation or to establish, exercise, or defend a legal claim. Support correspondence is kept for 24 months. Technical logs are kept for 12 months.

We use encryption in transit, hashed passwords, access controls limiting staff access to what their role requires, and monitoring for unauthorised access. No system is completely secure. If an eligible data breach occurs, we will notify affected individuals and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme, and we will notify the Information Commissioner’s Office in the United Kingdom within 72 hours where the breach is likely to result in a risk to your rights.

You may ask us to:

• confirm whether we hold personal information about you and give you access to it;
• correct information that is inaccurate, out of date, incomplete, irrelevant, or misleading;
• delete your account and the information associated with it;
• restrict our processing, or object to processing based on our legitimate interests;
• provide your information in a structured, commonly used, machine-readable format, or transmit it to another controller;
• withdraw your consent where we rely on it.

Write to cosmicstrike@mailfence.com. We will respond within 30 days and we do not charge a fee for a routine request. We may ask you to verify your identity first. If we refuse a request in whole or in part, we will explain why in writing and tell you how to complain. We do not make decisions about you based solely on automated processing that would produce legal effects or similarly significant effects for you.

If you have a privacy complaint, write to us first at cosmicstrike@mailfence.com and we will investigate and respond within 30 days. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner at oaic.gov.au, or, in the United Kingdom, to the Information Commissioner’s Office at ico.org.uk.

The Site is for adults aged 18 and over. We do not knowingly collect information from anyone below that age. If you believe a minor has created an account, contact cosmicstrike@mailfence.com and we will close the account and delete the information.

We may update this policy. The current version is always available at cosmicwheelplay.com/privacy with its effective date. Where a change is material we will notify registered users before it takes effect.

Derek Anderson, Cosmic Strike Ltd, 11-12 Tokenhouse Yard, London EC2R 7AS, United Kingdom · cosmicstrike@mailfence.com