Effective Date: 31 March 2026
Last Updated: 31 March 2026

Free Spins Atlas (“we”, “us”, “our”) is committed to protecting your privacy and handling your personal information responsibly, transparently, and in accordance with the New Zealand Privacy Act 2020. This Privacy Policy explains what information we collect, how we use it, how we store and protect it, and your rights regarding that information. By accessing or using the Free Spins Atlas (“the Site”), you acknowledge that you have read and understood this Privacy Policy.

1. About Free Spins Atlas

Free Spins Atlas is a free-to-play social entertainment platform that offers browser-based games themed around tropical coral reefs. Our games are designed purely for entertainment and use virtual coral points as a fun score-tracking mechanism. Coral points hold no monetary value and cannot be deposited, withdrawn, purchased, or exchanged for real money, prizes, or goods of any kind. We do not operate a gambling service, and no real-money transactions take place on this Site.

2. Information We Collect

Free Spins Atlas is designed to operate with minimal data collection. We do not require you to register an account, provide your name, create a password, or supply any personal information to use our games. Below is a comprehensive breakdown of the categories of information we may encounter.

2.1 Information You Voluntarily Provide

If you choose to contact us through our contact form or email address, you may provide your name, email address, and the content of your message. We only collect this information when you actively and voluntarily submit it to us. We do not collect personal information through any other means. We will never ask you to supply sensitive personal information such as financial details, government identifiers, or health records.

2.2 Automatically Collected Technical Data

When you visit our Site, our web server may automatically collect certain technical data, including your Internet Protocol (IP) address, browser type and version, operating system, referring URL, pages visited, time and date of your visit, and approximate geographic region. This data is collected through standard web server logs and is used solely for the purposes of maintaining site security, monitoring site performance, and understanding aggregate usage patterns. We do not use this data to identify individual users or build personal profiles.

2.3 Cookies and Local Storage

Our Site uses essential cookies and browser local storage to ensure core functionality. Specifically, we use a local storage entry to remember whether you have accepted our cookie notice, and we may use session cookies to maintain site functionality during your visit. We do not use advertising cookies, tracking pixels, third-party analytics platforms, or any form of cross-site tracking technology. For full details on our cookie practices, please see our Cookie Policy.

2.4 Information We Do Not Collect

We do not collect payment information, bank details, credit card numbers, or any financial data. We do not collect identity documents, government-issued identification numbers, tax file numbers, or IRD numbers. We do not collect health information, biometric data, or information about your racial or ethnic origin, political opinions, religious beliefs, or sexual orientation. We do not collect gameplay data linked to identified individuals, nor do we track individual play sessions, outcomes, or behavioural patterns for profiling purposes.

3. How We Use Your Information

Any information we collect is used strictly for the following purposes:

• Responding to enquiries: If you contact us, we use your name and email address solely to respond to your message. We do not add you to any marketing list or share your contact details with third parties.
• Site operation and security: Technical data collected through server logs is used to ensure the Site functions correctly, to identify and address security threats, and to monitor uptime and performance.
• Legal compliance: We may use or disclose information if required to do so by law, by a court order, or by a regulatory authority in New Zealand.
• Improving our services: Aggregate, non-identifiable usage statistics may be used to understand which pages and games are most popular, enabling us to improve the user experience. This data is never linked to individual users.

4. Legal Basis Under the NZ Privacy Act 2020

The New Zealand Privacy Act 2020 establishes thirteen Information Privacy Principles (IPPs) that govern the collection, use, storage, and disclosure of personal information. We are committed to compliance with all applicable IPPs, including but not limited to the following:

• IPP 1 — Purpose of collection: We only collect personal information for a lawful purpose directly connected to our activities, and only where the collection is reasonably necessary for that purpose.
• IPP 2 — Source of information: We collect personal information directly from the individual concerned (i.e., when you voluntarily submit a contact form).
• IPP 3 — Collection of information: When we collect personal information, we take reasonable steps to ensure you are aware of the purpose of collection, the intended recipients, and your rights of access and correction.
• IPP 4 — Manner of collection: We do not collect personal information by unlawful means, deception, or in a manner that is unfair or unreasonably intrusive.
• IPP 5 — Storage and security: We take reasonable precautions to protect personal information from loss, unauthorised access, misuse, modification, or disclosure.
• IPP 6 — Access to personal information: You have the right to request access to any personal information we hold about you. We will respond to such requests promptly and within 20 working days as required by the Act.
• IPP 7 — Correction of personal information: You have the right to request correction of any personal information we hold about you that is inaccurate, incomplete, or misleading.
• IPP 8 — Accuracy: Before using personal information, we take reasonable steps to ensure it is accurate, complete, and not misleading.
• IPP 9 — Retention: We do not retain personal information for longer than is necessary for the purposes for which it was collected.
• IPP 10 — Use of information: We only use personal information for the purpose it was collected, unless an exception applies under the Act.
• IPP 11 — Disclosure: We do not disclose personal information to third parties except where required by law or with your consent.
• IPP 12 — Cross-border disclosure: We do not transfer personal information outside of New Zealand unless we are satisfied that the recipient is subject to comparable privacy protections.
• IPP 13 — Unique identifiers: We do not assign unique identifiers to individuals for the purpose of our operations.

5. Data Storage and Security

Any personal information you provide (such as contact form submissions) is stored securely on servers protected by industry-standard security measures, including HTTPS encryption, firewall protection, and access controls. We limit access to personal information to authorised personnel who require it for the purposes described in this policy. We regularly review our security practices to ensure they remain appropriate and effective.

Server logs containing technical data are retained for a maximum of 90 days before being automatically purged. Contact form submissions are retained only for as long as necessary to respond to your enquiry, and no longer than 12 months unless ongoing correspondence requires retention. We do not sell, rent, or lease personal information to any third party under any circumstances.

6. Third-Party Services

Free Spins Atlas uses a minimal number of external services to operate the Site. These include Google Fonts for typography delivery. Google Fonts may log your IP address and browser information when fonts are loaded. We do not use Google Analytics, Facebook Pixel, advertising networks, or any third-party tracking or behavioural profiling services. We do not embed third-party widgets, social media trackers, or external scripts beyond essential web fonts.

7. Children’s Privacy

Free Spins Atlas is intended for individuals aged 18 years and over. We do not knowingly collect personal information from anyone under the age of 18. If we become aware that we have inadvertently collected information from a minor, we will take immediate steps to delete that information. If you believe that a person under 18 has provided us with personal information, please contact us at contact@freespinsatlas.com so that we can address the matter.

8. Your Rights

Under the New Zealand Privacy Act 2020, you have the following rights in relation to personal information we may hold about you:

• Right of access: You may request a copy of any personal information we hold about you.
• Right of correction: You may request that we correct any inaccurate or incomplete personal information.
• Right to withdraw consent: Where we have collected information based on your consent, you may withdraw that consent at any time.
• Right to complain: If you believe we have breached the Privacy Act 2020, you have the right to lodge a complaint with the Office of the Privacy Commissioner of New Zealand.

To exercise any of these rights, please contact us at contact@freespinsatlas.com with the subject line “Privacy Request”. We will acknowledge your request within five working days and provide a substantive response within 20 working days.

9. Office of the Privacy Commissioner

If you are not satisfied with our response to a privacy request or complaint, you may contact the Office of the Privacy Commissioner of New Zealand:

• Website: privacy.org.nz
• Phone: 0800 803 909
• Email: enquiries@privacy.org.nz

10. Data Breach Notification

In the event of a notifiable privacy breach as defined under Part 6 of the Privacy Act 2020, we will notify the Office of the Privacy Commissioner and affected individuals as soon as practicable, and no later than 72 hours after becoming aware of the breach. Our notification will include a description of the breach, the type of personal information involved, the likely consequences, and the steps we have taken or propose to take to address the breach and mitigate potential harm.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make changes, we will update the “Last Updated” date at the top of this page. We encourage you to review this policy periodically. If we make material changes that significantly affect how we handle personal information, we will provide a prominent notice on our Site. Your continued use of the Site after any changes indicates your acceptance of the updated Privacy Policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

• Email: contact@freespinatlas.com
• Subject Line: Privacy Enquiry
• Contact Page: freespinsatlas.com/contact.php

We value your privacy and are committed to being transparent about our practices. Thank you for trusting Free Spins Atlas with your time and for taking the time to read this policy.