NexaWin Privacy Policy

These Data Processing & Privacy Policy are adopted by NovaPlay N.V., Chuchubiweg 17, Willemstad, Curacao (“NovaPlay”, “we,” “us,” “our”) and apply when a visitor (“Visitor”, “You”) visits our website, novaplay.tech (the “Website”) and provides personal data in order to use the (functions of) our Website.

We respect your privacy and are committed to protecting and processing your personal data to the extent collected by us in accordance with Curaçao’s National Ordinance Personal Data Protection (Landsverordening bescherming persoonsgegevens (LBP) No. 84 dated 4 September 2010) and any data protection or privacy laws applicable to each respective Party.

1. Purpose of this Policy

The purpose of this Policy is to inform you how we look after your personal data when you visit our Website and sets out the terms and conditions which we follow in order to protect your privacy. It describes the conditions under which we may collect and process Your Personal Data in order to ensure their security and confidentiality.

2. Principles

We fully respect Your fundamental rights and consider protection of Your Personal Data to be a priority. Accordingly, when processing Your Personal Data, We follow the following basic principles:

• We collect and process Your Personal Data only to the extent that is necessary for specified, explicit, and legitimate purposes as outlined in this Privacy Policy, and We do not process it further in any manner incompatible with the purposes for which it has been collected.
• We make reasonable efforts to ensure that Your Personal Data is accurate and, where necessary, updated with regard to the purposes of the processing, taking all reasonable steps to immediately delete or correct it in case of inaccuracy.
• We submit Your Personal Data only for lawful and fair processing, and we maintain full transparency vis-à-vis the way we handle Your Personal Data.
• We process Your Personal Data in a manner that guarantees its security by using appropriate technical and organizational measures.
• We comply with all applicable legal and statutory obligations, as Data Controller of Your Personal Data.

We use cookies for optimization, evaluation of contacts, security and analytics in accordance with our separate Cookie Policy.

3. Types of Data Collected

We may collect and process the following data upon accessing our Website:

• IP Address
• Age confirmation
• User’s device data
• Browsing data
• General communication data
• Information on user preferences regarding the Website

4. Legal Basis and Purpose for Data Collection & Processing

We may collect and process Your Personal Data to fulfil the obligations under the Terms and Conditions and to comply with our legal obligations. In addition, we collect and process Your Personal Data for the following purposes:

• Administration and development of the Website.
• Enhancement of User’s experience.
• Detection, investigation and prevention of fraudulent activity and other illegal activities and protection of Your rights and our own rights.
• Performing statistical and other research.
• Statistical analysis of information for enhancement of the Website and the Services.
• Verifying compliance with the Terms and Conditions of the Website.

We may request and process additional Personal Data only with Your lawful and unambiguous consent for the following purposes:

• Commercial communication, marketing and advertising of Our Services or third-party Services.
• For personalized market research and/or analysis purposes to better understand Your needs, preferences, interests, experiences and/or habits as a consumer.

You have the right to withdraw Your consent to Our processing of Your Personal Data at any time in writing to Our contact details mentioned in this Policy. Withdrawal of Your consent does not affect the lawfulness of the treatment of Your Personal Data prior to its revocation.

5. Data Recipients

The processing of Your Personal Data by Our Data Processors is done under a contract compelling Data Processors to the same level of data protection provided under this Privacy Policy in accordance with applicable laws.

We will not disclose Your Personal Data to third parties located outside of Curaçao unless such cross-border data transfer complies with the conditions set out under the LBP, including ensuring an adequate level of protection for your data. Additionally, We will update this Privacy Policy to reflect any cross-border data transfers and the relevant safeguards implemented for Your privacy.

In the event that We are required by a court or other competent administrative authority pursuant to an investigation relating to unlawful activities such as money laundering, or in any other case where We are legally bound to do so, the Company may transfer Your Personal Data to public authorities to the extent specified by applicable law.

6. Data Security and Confidentiality

In order to ensure the proper use and integrity of Your Personal Data and to prevent unauthorized or accidental access, processing, deletion, alteration or other use, the Company applies appropriate internal policies and takes all appropriate organizational, technical and procedural security measures, as well as technical standards, in accordance with applicable laws and regulations.

The processing of Your Personal Data by the Company is conducted in a manner that ensures confidentiality and security, taking into account the latest developments, implementation costs and the nature, scope, context and purposes of the processing, as well as the risks for Your rights and freedoms, which are applicable in each circumstance.

Your Personal Data is processed solely by authorized personnel of the Company, bound by strict obligations of confidentiality.

7. Retention of Personal Data

We retain Your Personal Data for as long as is necessary to fulfil the relevant purposes of processing explained in this Policy, in accordance with the data minimization and storage limitation principles under the LBP.

Furthermore, the Company may retain Your Personal Data after the expiration of the relevant processing purposes in the following limited cases:

• In the event that there is a statutory legal obligation to do so under applicable Curaçao law.
• In case of any legal claims against the Company, for as long as necessary to defend Our rights and legitimate interests before any competent court or public authority.

After the required period of retention, Your Personal Data is safely erased from Our databases and systems. For more information about data retention terms, please contact Us at compliance@novaplay.tech.

8. Your Rights

Under the Curaçao National Ordinance Personal Data Protection (LBP), you possess the following explicit statutory rights:

Right to Access: You have the right to request confirmation as to whether or not your personal data is being processed, alongside information related to its processing and a copy thereof.

Right to Rectification, Addition, and Erasure: You have the right to request that the Company correct, complement, or delete your personal data if the data is factually incorrect, incomplete, or irrelevant to the purpose for which it was gathered.

Right to Object: You have the right to object to the processing of your personal data on serious personal grounds justified by your specific situation. Furthermore, you may object to data processing designated for direct marketing purposes at any time, free of charge.