Privacy Policy

This Privacy Policy explains how Sugar96, operating via the website sugar96-aussie.com (Sugar96), collects, uses, stores, and discloses your personal information. It is intended for players, prospective players, and other visitors to our website and related services. By accessing or using our services, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy is effective from 1 January 2026 and replaces any previous versions published on our website.

Who We Are

For the purposes of this Privacy Policy, references to "Sugar96", "we", "us" or "our" mean the offshore online gambling operator that owns and operates the website https://sugar96-aussie.com targeting Australian players under the brand name Sugar96.

The operator is a private entity registered in Willemstad, Curaçao under a shell-company structure (exact company name, legal address, and registration number are not specified in publicly available records). The operator claims to hold a Curaçao eGaming sub-licence under Master Licence 1668/JAZ or 8048/JAZ (status unverified and subject to clarification).

Some payment processing activities for Sugar96 may be performed by an affiliated payment processing subsidiary based in Cyprus (exact legal name and address not specified).

Because our precise corporate registration details are not publicly verified, you should treat Sugar96 as an offshore operator. Nothing in this Privacy Policy should be read as indicating that Sugar96 is licensed or authorised in Australia.

Contact for Privacy Matters

We have appointed an internal contact responsible for privacy and data protection matters (Data Protection Officer-equivalent).

Email (primary privacy contact): [email protected]
Support email: [email protected] (can also be used for privacy questions)
Postal address: Due to the offshore and online nature of our operations, we do not provide a reliable physical mailing address in Australia. If you require written correspondence, please contact us via email first so that we can provide the most appropriate channel.

What Personal Data We Collect

We collect and process different categories of personal information when you visit sugar96-aussie.com, create an account, deposit or withdraw funds, or use our casino services.

Identification and Contact Data

Full name, date of birth, and gender (where provided).
Residential address, country of residence, and billing address.
Email address(es) and telephone number(s).
Verification documents for KYC/AML (e.g. copies of ID, passport, driving licence, utility bills, payment card screenshots with masked digits).

Account and Behavioral Data

Username, encrypted password, preferred language, time zone.
Account settings, communication preferences, responsible gambling settings.
Gameplay and betting history, including games played, stakes, wins/losses, game session times, bonus usage, tournament participation.
Interaction logs such as clicks, page views, referring URLs, time spent on pages, and navigation paths.
Communications with us, including emails, chat transcripts, and complaint records.

Technical Data

IP address, approximate geolocation inferred from IP.
Device information (device type, operating system, browser type and version, screen resolution, language settings, unique device identifiers where available).
Log data, including access times, login attempts, error logs, security events, and technical diagnostics.
Information collected through cookies, web beacons, pixels, and similar tracking technologies (see "Cookies & Tracking Technologies").

Payment and Financial Data

Payment method details (e.g. card type, partial card number, expiry date, e-wallet details, bank account IBAN/BIC where applicable).
Deposit and withdrawal history (amounts, currencies, timestamps, transaction identifiers).
Chargeback records, fraud risk scores, and related internal assessments.

Sensitive and Risk-Related Data

Data related to suspected fraud, money laundering, or other unlawful activities derived from our monitoring tools and third-party risk services.
Responsible gambling data such as self-exclusion status, time-out periods, limits you set, and interactions related to gambling harm.

Cookies and Similar Technologies

Session cookies to keep you logged in and manage navigation.
Persistent cookies to remember preferences, language, and consent choices.
Analytics cookies and web beacons to measure traffic and performance.
Advertising and affiliate tracking cookies to attribute traffic and measure campaign effectiveness, where permitted.

Legal Basis for Processing

Our processing of personal data is grounded in applicable data protection principles recognised internationally, including those reflected in the EU General Data Protection Regulation (GDPR) and leading privacy frameworks. While Sugar96 is not established in the EU and is not an Australian-licensed operator, we apply similar concepts of lawful processing as a matter of good practice.

Performance of a Contract

Creating and managing your Sugar96 player account.
Providing access to games, bonuses, and related casino services.
Processing deposits, bets, winnings, withdrawals, and loyalty rewards.
Providing customer support and handling your requests or complaints.

Compliance with Legal and Regulatory Obligations

Know-Your-Customer (KYC) and Anti-Money Laundering (AML) checks, including identity verification, ongoing monitoring, and enhanced due diligence.
Prevention, detection, and reporting of fraud, money laundering, and other offences to relevant financial institutions, payment service providers or, where applicable, regulatory bodies in Curaçao or other jurisdictions in which we operate.
Record-keeping required by our claimed licensing framework or by applicable financial and tax laws in relevant jurisdictions.

Legitimate Interests

Securing our systems, preventing unauthorised access, and ensuring service integrity and reliability.
Monitoring gameplay to detect irregular patterns, abuse of bonuses, or breaches of our Terms & Conditions.
Improving our website, products, and services through analytics and statistical reporting (using pseudonymised or aggregated data where possible).
Establishing, exercising, or defending legal claims and managing disputes.

Consent

Sending direct marketing communications (email, SMS, push notifications) about Sugar96 promotions, new games, and offers where required by law.
Placing or reading non-essential cookies (especially advertising and certain analytics cookies) on your device, depending on your jurisdiction and browser settings.
Using certain optional features or sharing data with advertising networks or affiliates for personalised offers, where you explicitly agree.

Where we rely on consent, you may withdraw it at any time (see "Your Rights"). Withdrawal of consent will not affect the lawfulness of processing prior to withdrawal.

Purpose of Processing

We process your personal data only for specific, explicit, and legitimate purposes, which include:

Account registration and management: To create, verify, and manage your Sugar96 account, including authentication, password management, and profile settings.
Provision of gaming services: To operate casino games, manage bets, calculate and credit winnings, administer bonuses and loyalty programs, and provide other gaming-related functionalities.
Payment processing: To facilitate deposits and withdrawals, verify ownership of payment methods, process refunds and chargebacks, and reconcile accounts with our payment processors.
Customer support and communication: To respond to your inquiries, handle complaints, send transactional messages (such as deposit confirmations, security alerts, or account notices), and provide service updates.
Service improvement and analytics: To analyse website usage, identify technical issues, optimise performance, develop new features, and improve user experience using aggregated or pseudonymised data where possible.
Marketing and promotions: To send marketing communications (where permitted), personalise offers, run targeted campaigns, measure their effectiveness, and manage affiliate relationships.
Fraud prevention and security: To monitor accounts and transactions for suspicious activity, prevent bonus abuse, manage risk, enforce our Terms & Conditions, and protect our rights and the rights of our players.
Legal and regulatory compliance: To fulfil KYC/AML obligations, keep legally required records, respond to lawful requests from competent authorities in relevant jurisdictions, and comply with applicable laws to which we are subject.

Disclosure & Sharing

We do not sell your personal data. However, we may share your information with carefully selected third parties for the purposes described in this Privacy Policy. Where personal data is disclosed, we seek to ensure that recipients apply appropriate confidentiality and security measures.

Payment and Financial Partners

Banks, card schemes, payment processors, e-wallet providers, and other financial intermediaries used for deposits and withdrawals.
Our Cyprus-based payment processing subsidiary (or other affiliated payment entities) involved in handling your transactions.

Service Providers and Technical Partners

Game providers and platform vendors supporting our casino games and related features.
IT hosting and cloud infrastructure providers, email service providers, data backup and disaster recovery providers.
Analytics and performance monitoring providers (for example, tools measuring site traffic, detecting errors, and improving user interface).
Identity verification, KYC and AML screening providers, fraud detection services, and risk-scoring tools.

Affiliates and Marketing Partners

Affiliate networks and partners who refer players to Sugar96, to attribute traffic and calculate commissions.
Advertising networks and campaign managers (where permitted by applicable law and where we rely on your consent for non-essential cookies and personalised marketing).

Regulators, Authorities, and Dispute Bodies

Regulatory and supervisory authorities in Curaçao or other relevant jurisdictions in connection with our claimed licence or compliance obligations.
Law enforcement agencies, courts, and governmental bodies when we are required to do so by applicable law or when disclosure is necessary to establish, exercise, or defend legal claims.
Alternative dispute resolution (ADR) bodies or complaint schemes where you initiate a dispute process.

Corporate Transactions

Prospective buyers, investors, or merger partners (and their advisers) in the event of a proposed sale, merger, restructuring, or similar corporate transaction. In such cases, data will be shared under confidentiality obligations and, where feasible, in pseudonymised form.

Other Disclosures

Where you have provided explicit consent for a specific disclosure.
Where necessary to protect the vital interests of you or another person, or to protect our legitimate rights, property, or safety.

International Transfers

Sugar96 operates as an offshore online gambling service. As a result, your personal data may be transferred to, and processed in, countries outside your country of residence, including:

Curaçao, where our operator entity is registered and where elements of our platform and compliance functions may be located.
Cyprus, where an affiliated payment processing subsidiary is based.
Other countries in the European Economic Area (EEA) or outside it, where our service providers (such as hosting, analytics, or email providers) operate data centres or support teams.

These countries may have data protection laws that are different from those in your home jurisdiction and may not provide the same level of protection as, for example, the GDPR or the Australian Privacy Act 1988 (Cth). Where reasonably possible and appropriate, we seek to implement contractual safeguards with our service providers and partners, such as:

Standard contractual clauses or similar data-protection terms reflecting recognised international standards.
Confidentiality obligations, access controls, and security requirements consistent with this Privacy Policy.
Technical measures such as encryption and pseudonymisation to reduce risks when data is transferred internationally.

By using Sugar96, you acknowledge that your data may be processed in these jurisdictions and that local authorities may, in certain circumstances, access it in accordance with their laws.

Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, to meet our contractual and legal obligations, and to protect our legitimate interests, after which it is securely deleted or irreversibly anonymised.

Retention Periods (Indicative)

Account and identification data: Generally retained for the duration of your active account and for up to 5 years after account closure, in line with typical KYC/AML record-keeping expectations for gambling and financial services in offshore jurisdictions.
Payment and transaction data: Typically retained for 5 - 7 years after the relevant transaction to comply with accounting, tax, AML, and dispute-resolution time limits.
Gameplay and behavioural data: Retained for the lifetime of the account and for up to 5 years after closure for fraud-prevention and dispute-handling purposes, and in aggregated form for analytics.
Customer support and complaint records: Retained for up to 5 years after resolution of the issue, or longer where necessary for ongoing disputes or legal claims.
Marketing data: Retained until you withdraw your consent or object to marketing, after which we will cease marketing communications and keep only minimal records to respect your preferences.
Technical logs and security data: Retained for periods ranging from several months up to 2 years, depending on the nature of the logs and the necessity for security and fraud-prevention analysis.

Deletion Criteria

Data is no longer necessary for the purposes for which it was collected or otherwise processed.
Applicable statutory or regulatory retention periods have expired.
You have lawfully exercised your right to erasure and no overriding legal grounds for retention exist.
We decide to cease operating certain services or markets, and further retention is not required by law.

Where we cannot fully delete data due to technical or legal reasons, we will endeavour to store it securely, restrict access, and, where possible, anonymise or pseudonymise it.

Your Rights

While Sugar96 is an offshore operator and not formally subject to all privacy regimes referenced below, we aim, as a matter of policy, to align our practices with recognised international standards such as the GDPR and, where relevant, elements of Mexican and other data-protection frameworks. This section summarises the key rights you may have, depending on your jurisdiction and applicable law.

Access to Your Data

You may request confirmation of whether we process your personal data and obtain a copy of such data, together with information about how it is used, disclosed, and retained.

Correction (Rectification)

You may request that inaccurate or incomplete personal data we hold about you be corrected or updated, particularly identity, contact, and payment details.

Deletion (Erasure)

You may request deletion of your personal data where:
- it is no longer necessary for the purposes for which it was collected;
- you have withdrawn consent (where consent was the sole basis); or
- you believe the processing is unlawful and no overriding legitimate grounds apply.
We may retain certain data where required by KYC/AML, financial, or legal obligations, or where necessary for the establishment, exercise, or defence of legal claims.

Restriction of Processing

You may request that we restrict processing of your data in certain circumstances, for example:
- while we verify its accuracy following your challenge;
- where processing is unlawful, but you request restriction instead of deletion; or
- where we no longer need the data, but you require it for legal claims.

Objection to Processing

You may object to certain processing based on our legitimate interests (including profiling), particularly for direct marketing. If you object to direct marketing, we will stop such processing.

Data Portability

Where technically feasible and required by relevant law, you may request a copy of certain personal data in a structured, commonly used, and machine-readable format and ask us to transmit it to another controller, where the processing is based on consent or contract and is carried out by automated means.

Withdrawal of Consent

Where processing is based on your consent (e.g. for marketing or certain cookies), you may withdraw this consent at any time via:
- the "unsubscribe" links in marketing emails;
- your account communication preferences; or
- contacting us at [email protected].

Procedures, Timeframes, and Cost

How to exercise your rights: Send a clear request to [email protected] or [email protected] from the email associated with your account, or otherwise provide sufficient identification so we can verify your identity.
Verification: For your security, we may ask for additional information (such as confirming account details or providing ID) to ensure that we only act on requests from the rightful account holder.
Response time: We aim to respond to your request within 30 days of receiving a complete and verifiable request. Complex or multiple requests may require more time; in that case, we will inform you of any extension and the reasons.
Fees: We will handle your request free of charge unless it is manifestly unfounded or excessive, in which case we may either charge a reasonable administrative fee or refuse to act on the request, consistent with applicable legal standards.

Nothing in this section creates enforceable rights under Australian law against Sugar96 where such rights would otherwise not apply. However, we voluntarily adopt these mechanisms to enhance transparency and trust.

Cookies & Tracking Technologies

We use cookies and similar tracking technologies on sugar96-aussie.com to provide, protect, and improve our services.

Types of Cookies

Session cookies: Temporary cookies that exist only while your browser is open and are deleted when you close it. They are used to maintain your logged-in session and support navigation.
Persistent cookies: Cookies that remain on your device for a set period or until you delete them. They allow us to remember your preferences, such as language, and to recognise you when you return.
First-party cookies: Cookies set directly by Sugar96 for core website functions.
Third-party cookies: Cookies set by third-party service providers, such as analytics tools, advertising networks, or affiliates.

Purposes of Cookies

Strictly necessary / functional: Required for the website to function correctly, such as maintaining sessions, handling security (e.g. CSRF protection), and enabling core account features.
Preferences: To remember your choices, including language, region, and display settings.
Analytics and performance: To collect information about how visitors use our website (e.g. pages visited, time spent, error messages) so we can improve layout, content, and performance.
Advertising and affiliate tracking: To measure the effectiveness of marketing campaigns, attribute players referred by affiliates, and, where permitted, present offers that may be more relevant to you.

Managing Cookies

You can manage or delete cookies using your browser settings. Most browsers allow you to:
- block all cookies;
- block cookies from specific sites;
- delete existing cookies; or
- receive notifications before a cookie is stored.
Disabling strictly necessary cookies may affect the operation of our website and prevent you from logging in or playing games.
Where we provide an internal cookie or privacy settings panel, you may use it to manage non-essential cookies such as analytics or advertising cookies in addition to browser controls.

By continuing to use our website without adjusting your browser or internal settings to reject cookies, you acknowledge and agree to our use of cookies as described in this section.

Data Security

We implement a combination of technical, organisational, and administrative measures designed to protect your personal data against unauthorised access, loss, misuse, alteration, or disclosure. However, no system can be guaranteed to be 100% secure, and we cannot accept liability for breaches outside our reasonable control.

Technical Measures

Encryption in transit: We use Transport Layer Security (TLS 1.2 or higher) to encrypt communications between your browser and our servers where supported.
Encryption at rest: Sensitive data (such as passwords and certain payment-related data) is stored using industry-standard hashing and encryption algorithms.
Access controls: Access to production systems and databases is restricted to authorised personnel on a need-to-know basis using authentication, role-based access controls, and, where feasible, multi-factor authentication (MFA).
Network and application security: We deploy firewalls, intrusion detection or prevention tools, and other measures to monitor and protect our infrastructure against malicious activity.

Organisational Measures

Internal policies: We maintain internal policies and procedures governing data protection, information security, and acceptable use of systems.
Staff training: Staff and contractors with access to personal data are expected to receive appropriate training on confidentiality and data-protection responsibilities.
Vendor management: We seek to engage service providers who apply security standards consistent with our own and who commit contractually to protect your data.

Monitoring and Incident Response

We monitor our systems for suspicious activity, anomalies, and potential vulnerabilities.
We maintain procedures for responding to security incidents, assessing their impact, and taking remedial steps.
Where required by applicable law and where we are able to contact you, we will notify you and, where relevant, authorities of certain data breaches that are likely to result in a high risk to your rights and freedoms.

While we reference common security frameworks such as ISO 27001 and SOC 2 as benchmarks, Sugar96 is not formally certified under these standards as of 2026. Our security posture may evolve over time as we enhance our controls and infrastructure.

Complaints & Contacts

If you have questions, concerns, or complaints about how we handle your personal data, we encourage you to contact us first so we can try to resolve the issue directly.

How to Contact Us

Privacy and support email: [email protected], [email protected]
Press enquiries: [email protected] (not intended for privacy requests but may be used if other channels fail).

Internal Complaint Procedure

Submission: Send us an email describing your concern in as much detail as possible, including relevant account identifiers and any supporting evidence.
Acknowledgement: We aim to acknowledge receipt of your complaint within 7 calendar days.
Investigation: We will investigate your complaint, which may involve reviewing logs, communications, and interactions with third-party providers.
Response: We aim to provide a substantive response within 30 days of receiving your complete complaint. If we are unable to meet this timeframe due to complexity or external dependencies, we will inform you of the delay and provide an updated estimate.
Resolution: Where we identify an issue, we will explain the corrective measures taken. Where we consider our processing to be compliant, we will explain our reasoning and reference this Privacy Policy and, where relevant, applicable laws or contractual obligations.

Escalation to Supervisory or Regulatory Authorities

Because Sugar96 operates offshore under a claimed Curaçao licence and is not licensed in Australia, your options to escalate privacy complaints to formal authorities may be limited and depend on your jurisdiction. Potential avenues include:

Curaçao eGaming (licensing-related complaints): You may submit a complaint using the Curaçao eGaming public complaint form if you believe we are in breach of our claimed licence obligations: https://curacao-egaming.com/public-and-players/complaints. Please note that this body primarily deals with gambling-related complaints and may not address all privacy issues.
Australian authorities: The Australian Communications and Media Authority (ACMA) enforces the Interactive Gambling Act 2001 and may provide information on offshore gambling services (see https://acma.gov.au/publications). However, Sugar96 is not licensed by Australian regulators, and privacy complaints may fall outside their practical remit.
Local data protection authority: Depending on your country of residence, you may have the right to lodge a complaint with your local data protection authority or similar body in relation to our handling of your personal data.

We recommend that you contact us first so we can attempt to resolve any concerns promptly and directly.

Updates

We may modify this Privacy Policy from time to time to reflect changes in our services, legal obligations, technical infrastructure, or data-handling practices. The most recent version will always be available on sugar96-aussie.com.

Notification of Changes

Minor changes: For non-material updates (such as clarifications, formatting, or organisational adjustments that do not materially affect your rights or obligations), we may update the Privacy Policy without specific notification, other than updating the "Last updated" date below.
Material changes: For changes that significantly affect how we process your data or your rights (for example, new categories of data, new purposes, or expanded sharing with third parties), we will:
- provide notice at least 30 days before the changes take effect, where reasonably practicable; and
- inform you through one or more channels, such as email, in-site notifications, banners, or messages in your account dashboard.

Your Options

By continuing to use Sugar96 after the effective date of updated terms, you are deemed to have accepted the revised Privacy Policy.
If you do not agree with material changes, you may choose to stop using our services and, where available, request account closure and exercise your data-protection rights (including access, correction, or deletion, subject to legal retention requirements).

Last updated: January 2026