1. Data controller
The controller responsible for personal data processed through neonshuffle.com is:
- Controller
- NeonShuffle Limited
- Address
- 390 Devon Street East, Strandon, New Plymouth 4312, New Zealand
- hello@neonshuffle.com
- Website
- neonshuffle.com
For any privacy question or request, write to the email address above with "Privacy" in the subject line, or use the contact form and choose "Privacy or data request".
2. Scope
This policy covers the Neon Shuffle website and games. Neon Shuffle is a social casino for adults 18+ with no real-money gambling and no real-world prizes. We designed it to work without accounts, so we process very little personal data.
3. What we collect
Information you give us
- Contact form and emails: your name, email address, the topic you choose, your message, the time of sending and your IP address (kept for spam and abuse prevention).
- Purchases (when checkout is enabled): an order reference, the pack bought, the amount, currency, country and the email address you give at checkout. Card details are collected by the payment provider, not by us.
Information collected automatically
- Server logs: our hosting server records IP address, browser type, requested page, referring page and time of request.
Information that stays on your device
- Your Sparks balance, the time of your last daily gift, your age confirmation, your cookie choices and the start time of your play session are stored in your browser. We do not receive this information. The Cookie Policy lists each item.
4. Purposes and legal bases
| Purpose | Data | Legal basis (GDPR / UK GDPR) |
|---|---|---|
| Replying to your messages and requests | Contact form and email data | Legitimate interests in answering enquiries; steps taken at your request before a contract |
| Preventing spam, fraud and abuse | IP address, form timing data, server logs | Legitimate interests in keeping the Site secure |
| Selling and delivering Spark packs, handling refunds | Purchase data | Performance of a contract |
| Accounting and tax records | Purchase data | Legal obligation |
| Recording your cookie choices | Consent cookie | Legal obligation |
| Handling privacy requests and legal claims | Request details and correspondence | Legal obligation; legitimate interests |
5. What we do not do
- We do not sell personal data or share it for cross-context behavioural advertising.
- We do not use analytics or advertising cookies at present.
- We do not make decisions about you based solely on automated processing.
- We do not send marketing emails.
6. Who receives data
- Our hosting provider, which stores the Site and its server logs.
- Our email provider, which delivers messages between us and you.
- A payment provider, when checkout for Spark packs is enabled, acting under its own privacy terms for card data.
- Professional advisers such as accountants and lawyers, where needed.
- Public authorities, where the law requires us to disclose information.
Service providers act on our instructions and are bound by confidentiality and data protection terms.
7. International transfers
Some providers may process data outside your country, including outside the European Economic Area or the UK. Where that happens, we rely on an adequacy decision or on safeguards such as the European Commission's Standard Contractual Clauses and the UK addendum.
8. How long we keep data
- Contact messages: 24 months after the conversation ends, then deleted.
- Server logs: up to 90 days, unless needed to investigate a security incident.
- Purchase records: as long as tax and accounting law requires, typically up to 10 years.
- Browser storage: until it expires or you clear it (see the Cookie Policy).
9. Your rights
Depending on where you live, you can ask us to:
- give you access to your personal data and a copy of it;
- correct inaccurate data or complete incomplete data;
- delete your data;
- restrict or object to our processing, including processing based on legitimate interests;
- provide your data in a portable format;
- withdraw consent at any time, without affecting earlier processing.
We reply within one month, extendable where the law allows. We may need to confirm your identity first. Exercising your rights is free unless a request is clearly unfounded or excessive.
10. Regional notices
- European Economic Area and Switzerland: you may complain to the data protection authority in your country of residence or work.
- United Kingdom: you may complain to the Information Commissioner's Office (ICO).
- United States: residents of California and other states with privacy laws have the right to know, access, correct and delete personal information, and to opt out of its sale or sharing. We do not sell or share personal information and do not process sensitive personal information. We will not discriminate against you for exercising your rights. You may use an authorised agent.
- Canada, Australia, New Zealand, Japan, Brazil, South Africa and other countries: we honour the access, correction and deletion rights your local law provides, and you may contact your national privacy regulator.
11. Age limit
Neon Shuffle is only for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a minor has sent us personal data or made a purchase, contact us and we will delete the data and help with a refund.
12. Security
The Site is served over HTTPS. Contact messages are stored in a location that is not publicly accessible, and access is limited to people who need it. No system is perfectly secure, but we take reasonable technical and organisational measures to protect your data.
13. Changes
We will update this policy when our practices change, for example if we enable checkout or introduce analytics. The effective date above shows the current version.
14. Contact and complaints
NeonShuffle Limited, 390 Devon Street East, Strandon, New Plymouth 4312, New Zealand. Email: hello@neonshuffle.com. We would appreciate the chance to resolve any concern before you contact a regulator.