Privacy Policy

Introduction

1.1 This Privacy Policy applies to the website of Resolvo Curaçao N.V. and to the alternative dispute resolution services provided by Resolvo Curaçao N.V. ("Resolvo", "we", "us", "our").

1.2 Resolvo is an independent alternative dispute resolution provider based in Curaçao.

1.3 Resolvo provides ADR services in accordance with the applicable Curaçao legal and regulatory framework, including the National Ordinance on Games of Chance (Landsverordening op de Kansspelen, P.B. 2024, no. 157, "LOK"), the applicable Curaçao Gaming Authority ("CGA") framework, and Resolvo's published complaint procedure.

1.4 We are committed to protecting personal data handled through our website and in connection with our ADR services.

1.5 This Privacy Policy explains what data we collect, how we use it, with whom we may share it, how long we retain it, and what rights you may have.

Data Controller

2.1 The data controller is:

Personal Data We Collect

3.1 We may collect and process the following categories of personal data.

3.1 Data provided by players submitting a dispute

3.1.1 This may include:

1. full name and residential address;
2. player account ID at the relevant operator;
3. email address and other contact details;
4. date of the original complaint to the operator and the operator's final response;
5. description of the disputed conduct and the outcome sought;
6. supporting documents and evidence relevant to the dispute; and
7. identity verification documents, where required.

3.2 Data provided by operators

3.2.1 This may include:

1. company name and contact details;
2. account and transaction records relevant to the dispute; and
3. internal complaint correspondence.

3.3 Data collected automatically

3.3.1 This may include:

1. IP address and browser type;
2. website usage data through cookies and analytics tools; and
3. date and time of site visits.

How We Use Personal Data

4.1 We process personal data for the following purposes:

1. to assess, manage, and resolve ADR cases;
2. to comply with legal and regulatory obligations, including record-keeping, reporting, and cooperation with CGA monitoring;
3. to communicate with the parties to a dispute;
4. to maintain and improve the functionality of our website; and
5. to send operational communications regarding a case or website use.

Legal Basis for Processing

5.1 Depending on the circumstances, we process personal data because:

1. processing is necessary for the administration of the ADR process;
2. processing is necessary to comply with legal and regulatory obligations;
3. processing is necessary for our legitimate interests in operating a secure and functional website and ADR service; or
4. the data subject has given consent, where consent is required.

Disclosure of Personal Data

6.1 We do not sell personal data.

6.2 We may share personal data only where necessary and appropriate:

1. with the CGA, where required under the LOK, CGA policy, monitoring, or oversight;
2. with the operator party to a dispute, to the extent necessary for the ADR process;
3. with trusted service providers acting on our behalf under appropriate safeguards; and
4. where disclosure is required by law, court order, or competent regulatory authority.

Minors

7.1 Our services are not directed to individuals under the age of 18.

7.2 We do not knowingly collect or process personal data from minors.

7.3 If you believe that a minor has submitted personal data to us, please contact us at info@resolvocuracao.com.

Retention

8.1 We retain records of ADR cases for a minimum of five years from case closure.

8.2 Website analytics data may be retained for a shorter period.

8.3 Where retention is required by law or regulatory obligation, we retain data for the applicable period notwithstanding any erasure request.

Security

9.1 We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure.

9.2 Case files are handled confidentially and access is restricted to authorised personnel.

9.3 No transmission of data over the internet can be guaranteed to be completely secure.

Your Rights

10.1 Subject to applicable law, you may have the right to:

1. access the personal data we hold about you;
2. request correction of inaccurate or incomplete data;
3. request erasure of data, subject to legal and regulatory retention obligations;
4. object to or restrict certain types of processing; and
5. lodge a complaint with the relevant data protection authority.

10.2 To exercise these rights, contact us at info@resolvocuracao.com.

Cookies

11.1 Our website uses essential cookies to ensure functionality and may use analytics cookies to understand how visitors use the site.

11.2 Cookie preferences can be managed through browser settings.

Changes to This Policy

12.1 We may update this Privacy Policy from time to time.

12.2 The current version will always be published on the website, and the date of the last revision will be indicated at the top of the page.

12.3 Continued use of the website following an update constitutes acceptance of the revised policy.

Contact

13.1 For any questions regarding this Privacy Policy or the processing of personal data, please contact: