Privacy Policy
This Privacy Policy explains how The Clubhouse collects, uses, stores, and protects personal information belonging to players who access and use our services. It covers the categories of data we gather, the purposes for which we process that data, the role of cookies and similar technologies, how we work with third parties, how long information is retained, and the rights available to you as a data subject. This document applies to all visitors and registered account holders of The Clubhouse and should be read together with our terms and conditions and our responsible gaming information. By registering an account or otherwise using our platform, you acknowledge that your personal data will be handled in the manner described below.
Who We Are
The Clubhouse is operated under the framework of the licences held by the operator, including authorisation referenced to the Tobique Gaming Commission and Anjouan Gaming. The service is provided with a dedicated focus on players in Australia, and all data-handling practices described in this policy are designed to meet recognised standards of privacy protection applicable to online gambling operators. Where local Australian privacy law imposes requirements that differ from or exceed general practice, we aim to align our procedures accordingly, though this policy is not a substitute for independent legal advice. References to “we”, “us”, or “our” throughout this document mean The Clubhouse and its operating entity.
Age and Eligibility Notice
The Clubhouse is intended solely for individuals who are at least 18 years of age, which is the recognised minimum legal age for gambling participation in Australia. We do not knowingly collect personal information from anyone under this age, and identity verification procedures are used specifically to confirm that account holders meet this threshold. If we become aware that an account has been opened by a person under 18, that account will be closed, any funds handled in accordance with our terms, and the associated data retained only as required for compliance and record-keeping purposes. Parents or guardians who believe a minor has attempted to register should contact our support channels so the matter can be addressed promptly.
Information We Collect
We collect personal information at various stages of your relationship with us, from initial registration through to ongoing account activity and, where applicable, account closure. Some information is provided directly by you, while other data is generated automatically through your use of the platform or supplied by trusted third parties such as payment providers and identity verification services. The table below summarises the main categories of information collected and typical examples within each category.
| Data Category | Examples | Primary Purpose |
|---|---|---|
| Identity data | Full name, date of birth, gender, government-issued ID details | Age and identity verification, fraud prevention |
| Contact data | Email address, residential address, phone number | Account communication, verification, security alerts |
| Financial data | Payment method details, transaction history, wallet or card identifiers | Processing deposits and withdrawals, KYC checks |
| Account and activity data | Login credentials, gameplay history, wagering activity, bonus usage | Account management, fair play monitoring, loyalty tracking |
| Technical data | IP address, device type, browser type, operating system | Security, fraud detection, service optimisation |
| Communication data | Support chat logs, emails, survey responses | Customer service, dispute handling |
| Marketing preferences | Opt-in or opt-out status for communications | Managing consent for promotional contact |
How We Use Your Information
Personal data is processed for a defined set of purposes connected to operating the platform responsibly and lawfully. These purposes include verifying your identity and age before permitting deposits or withdrawals, processing payment transactions through the methods available on the platform, administering your account including balance tracking, loyalty point accrual, and bonus eligibility checks, and detecting and preventing fraud, money laundering, or other prohibited activity. We also use data to respond to support enquiries, to maintain records required by our licensing obligations, and to monitor for signs of harmful gambling behaviour so that responsible gaming tools can be offered where appropriate. Where any bonus terms require verification of wagering activity, such as confirming that deposits made under a bonus arrangement have been wagered the required number of times or that maximum bet limits were respected while a bonus was active, transaction and gameplay data is reviewed for that specific compliance purpose only.
Legal Bases for Processing
We rely on a combination of legal bases to process personal data, depending on the purpose involved. Processing necessary to perform our contractual obligations to you, such as managing your account and processing transactions, is carried out on a contractual basis. Processing required to meet regulatory or licensing obligations, including identity verification and record-keeping, is carried out on the basis of legal obligation. Where processing serves our legitimate interests in preventing fraud or improving the security and functionality of the platform, this is balanced against your privacy rights. In limited cases, such as certain marketing communications, we rely on your consent, which you may withdraw at any time through the preferences available in your account or by contacting support.
Cookies and Similar Technologies
Our platform uses cookies and comparable tracking technologies to support core functionality, remember your preferences, and understand how the site is used. Cookies fall broadly into essential cookies, which are required for the platform to operate correctly and cannot be disabled without affecting core functions such as login and session security, and non-essential cookies, which support analytics, performance measurement, and personalisation of content. Most browsers allow you to manage or block cookies through their settings, though disabling essential cookies may prevent you from using certain features of the platform, including account access. We do not use cookies to determine your eligibility to gamble or to circumvent any self-exclusion or limit-setting tools you have activated.
Sharing of Information with Third Parties
We share personal information with select categories of third parties where necessary to operate the platform and meet our legal obligations. This includes payment service providers who process deposits and withdrawals across the methods available on the platform, identity verification and anti-fraud service providers who assist with know-your-customer checks, regulatory and licensing authorities where disclosure is required by law, and professional advisers such as auditors or legal counsel where necessary for compliance or dispute resolution. We do not sell personal information to third parties for their own independent marketing purposes. Any third party engaged to process data on our behalf is required to apply appropriate safeguards consistent with the standards described in this policy.
Cross-Border Data Transfers
Given the international nature of online gambling operations and the involvement of service providers located in different jurisdictions, personal data may be transferred to and processed in countries outside Australia. Where such transfers occur, we take reasonable steps to ensure that the receiving party maintains a level of data protection consistent with the principles set out in this policy, including through contractual safeguards where appropriate. If you would like further information about the general nature of these arrangements, you may contact us through the channels described below.
Data Retention
Personal data is retained for as long as necessary to fulfil the purposes described in this policy, including the duration of your active account relationship with us and any additional period required to meet legal, regulatory, tax, or dispute-resolution obligations. Identity verification records and transaction histories are typically retained for extended periods following account closure to satisfy anti-money-laundering and audit requirements. Where data is no longer required for these purposes, it is deleted or anonymised in accordance with our internal retention procedures. If you request account closure, certain records may nonetheless be retained where retention is legally mandated.
Your Rights
Depending on applicable law, you may have a number of rights concerning the personal data we hold about you. These commonly include the right to request access to the personal information we hold, the right to request correction of inaccurate or incomplete data, the right to request deletion of data where retention is no longer necessary or legally required, the right to object to or restrict certain forms of processing, and the right to withdraw consent for processing that relies on consent, such as marketing communications. Requests can be submitted through our support channels, and we will respond within a reasonable timeframe once your identity has been verified, which is necessary to protect your account from unauthorised access. In some circumstances, we may not be able to fully action a request, for example where retention is required for regulatory compliance, and we will explain the reason in such cases.
Data Security
We apply a range of technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, or disclosure. These measures include encryption of sensitive data during transmission, restricted internal access controls, and monitoring of systems for suspicious activity. While we take data protection seriously, no system can guarantee absolute security, and you also play a role in protecting your account by keeping login credentials confidential, using a strong password, and notifying us promptly if you suspect unauthorised access to your account.
Responsible Gambling and Data
Data collected during your use of the platform may also support the responsible gaming tools available to you. Where you set deposit limits, time-based limits, or activate self-exclusion, this information is recorded so that the relevant restriction can be applied consistently across your account. This use of data is intended solely to support player protection and is treated with the same level of confidentiality as other account information. We encourage all players to review the responsible gambling information made available on the platform and to make use of available limit-setting tools if they wish to manage their gambling activity more closely, particularly given that the minimum legal age for gambling in Australia is 18 and responsible play is expected of all account holders regardless of tenure or loyalty level.
Bonus-Related Data Handling
Where a player participates in an arrangement governed by bonus terms, certain account and transaction data is reviewed specifically to confirm compliance with the applicable conditions. This may include confirming that deposits meet the minimum threshold required, that wagering requirements such as a multiple applied to bonus funds have been satisfied within the applicable validity period, and that maximum bet limits were respected while a bonus was active. The table below summarises, for reference, the general structure of such conditions as they relate to data review, without constituting a promotional description of any offer.
| Condition Reviewed | General Rule |
|---|---|
| Minimum deposit per stage | Verified against payment records |
| Wagering requirement | Multiple applied to bonus funds and related winnings, tracked against gameplay data |
| Maximum bet while active | Monitored against wagering activity during the bonus period |
| Validity period | Time-limited window tracked from credit of the bonus |
| Eligible games | Contribution rates checked against specific titles, where applicable |
This data review process exists to ensure fairness and consistency for all players and is not intended to encourage participation in any bonus arrangement, which remains entirely optional and subject to the full terms available elsewhere on the platform.
Children’s Privacy
Our services are not directed at, and are not intended for use by, anyone under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected data from a person under the legal age, we will take steps to delete that information promptly, subject to any retention required for compliance investigation purposes.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or the services we offer. Where changes are material, we will take reasonable steps to bring them to your attention, such as through a notice on the platform or a direct communication to your registered contact details. Continued use of the platform following any update constitutes acceptance of the revised policy, and we encourage players to review this page periodically.
Contacting Us About Privacy
If you have questions about this Privacy Policy, wish to exercise any of the rights described above, or have concerns about how your personal data has been handled, you can reach our support team through the live chat facility available on the platform or by email, with responses typically provided within a reasonable timeframe. When contacting us regarding a privacy matter, please provide sufficient detail to allow us to identify your account and the nature of your request, while avoiding the inclusion of sensitive payment details in unencrypted communications. For general account and service information, further detail is also available through The Clubhouse and the other informational sections of the platform, including details on payment methods and the terms and conditions governing account use, alongside our responsible gaming resources for players who wish to manage their activity.
