Privacy Policy

This Privacy Policy explains how Winward, available via winward-au.com, collects, uses, discloses, and protects personal information of players and website visitors. It applies to all users who access or use this website, interact with our content, or communicate with us through any channel linked to winward-au.com. By using this website, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy is effective from 1 January 2026 and supersedes any earlier versions published on this site.

Who We Are

Observe: The project domain and brand are specified, but the underlying operator's full corporate details are not verifiable or fully disclosed in public sources, and the service targets Australia as an offshore offering.

Expand: To avoid misleading users and to comply with Australian consumer law principles regarding accurate representations, this Privacy Policy must clearly distinguish between (i) this review/information site Winward at winward-au.com and (ii) any third-party gambling operator(s) providing the Winward Casino service via external domains. Where exact corporate details are unknown or unverified, this must be transparently stated.

Reflect: We therefore provide the following identification and contact information based on currently available data, without creating the impression of holding an Australian licence or operating legally in Australia.

Site Owner and Nature of Service

• Service type: Winward at winward-au.com is an informational and review website focused on the offshore online casino brand "Winward Casino" ("Winward"). It is not an online casino, does not process real-money bets, and does not itself offer gambling services to users in Australia.
• Brand reference: Any references to "Winward" in this Privacy Policy are made solely for descriptive and review purposes concerning the offshore casino brand historically associated with domains such as winwardcasino.ag and winward.vip.

Operator and Registration Information (Disclosure Limits)

• Corporate entity: Publicly available sources and historical references associate Winward Casino with Blacknote Entertainment Group. However, the exact current operating company, its legal address, company registration number, tax identification, and active gaming licence details are not reliably verifiable as of 2026 for Australian purposes.
• Licensing in Australia: For the avoidance of doubt, Winward Casino is considered an illegal offshore gambling service for Australian residents, and mirror sites have been the subject of blocking requests by the Australian Communications and Media Authority (ACMA) under the Interactive Gambling Act 2001.
• Regulatory status disclaimer: Nothing in this Privacy Policy should be read as suggesting that Winward Casino or any associated entity holds a valid licence to provide gambling services in Australia.

Contact and Data Protection Responsibility

• Primary contact email for this site: [email protected] (general and privacy-related enquiries concerning Winward).
• Data protection contact: All privacy, data access, and complaint requests for this review site should be addressed to:
  • Email: [email protected]
  • Postal address: Not specified - correspondence is accepted electronically only at this time.
• Note on casino accounts: If you created an account with any external Winward Casino domain, your contractual relationship and data processing are governed by the privacy policy of that external operator. This Privacy Policy covers only processing performed via winward-au.com.

What Personal Data We Collect

Observe: We operate a review/affiliate-type site, which collects typical website, contact, and tracking data; we do not operate player gaming accounts or process wagers, but we may receive limited referral and analytics data from partners.

Expand: To ensure compliance with Australian privacy principles and international standards (e.g. GDPR-style transparency), we categorise data precisely by type and purpose, including technical and behavioural tracking, cookies, and any information you voluntarily submit.

Reflect: The categories below apply only to interactions with Winward at winward-au.com. Data processed by external casinos is covered by their own policies.

Identification and Contact Data

• Basic personal data: Your name, email address, and any other contact details you provide when:
  • Contacting us via email ([email protected]) or any contact form linked from this site;
  • Subscribing to newsletters or marketing communications, where offered;
  • Participating in surveys, feedback requests, or promotional activities hosted by this site.

Technical and Usage Data

• Device and connection data: IP address, approximate geolocation inferred from IP, browser type and version, operating system, device identifiers, language settings, referrer URL, and time of access.
• Server logs: Pages visited, date and time of requests, HTTP status codes, time spent on pages, click paths, and error logs. These are stored primarily for security, diagnostics, and analytics.

Behavioral and Interaction Data

• On-site behaviour: Clicks on links (including outbound links to casino or affiliate domains), scrolling behaviour, time spent on specific reviews or guides, and interaction with banners or comparison tables.
• Communication records: Content of emails and form submissions, including any information you voluntarily provide in enquiries or feedback.

Payment and Financial Data

• Review site scope: Winward does not process deposits, withdrawals, or wagers and does not collect card or bank details directly.
• Affiliate data: We may receive aggregated or pseudonymised performance reports from affiliate or advertising partners (e.g. conversions, clicks, revenue share amounts) but these reports do not typically contain directly identifiable payment data of individual users.

Cookies and Similar Technologies

• Cookies: Small text files placed on your device to enable core functionality, remember preferences, and analyse site usage.
• Tracking technologies: Web beacons, pixels, tags, and scripts used to measure marketing performance, attribute referrals (for example, when you navigate from winward-au.com to an external Winward Casino mirror domain), and improve user experience.
• Third-party tools: Analytics and advertising services (such as web analytics platforms) may place their own cookies when you visit this site; these cookies are subject to the respective third-party privacy policies.

Legal Basis for Processing

Observe: While Winward primarily targets Australian users, we may receive visits from other jurisdictions, including those where GDPR-like frameworks apply. We must therefore articulate clear legal bases grounded in consent, contract, legitimate interest, and legal obligations.

Expand: Given the offshore gambling context and ACMA's stance, we must ensure that any processing we undertake as a review site is minimised, transparent, and justifiable, especially for tracking, marketing, and anti-fraud functions.

Reflect: Our processing activities rely on the following legal grounds, as applicable:

• Consent:
  • Where required by law (including for certain cookies, marketing emails, or newsletter subscriptions), we obtain your explicit consent before activating non-essential tracking or sending direct electronic marketing.
  • You can withdraw your consent at any time by using unsubscribe links in emails, adjusting cookie preferences where offered, or contacting us at [email protected].
• Contractual necessity:
  • When you ask us to provide specific information, respond to your queries, or deliver a subscribed service (such as a newsletter), we process your contact and communication data as necessary to fulfil that request or service.
• Legitimate interests:
  • We process limited technical, analytical, and behavioural data to:
    • Secure our website and detect abuse or fraudulent activity (e.g. repeated automated requests, scraping, or attacks);
    • Measure the performance of our content and affiliate links;
    • Improve the usability, structure, and relevance of our reviews and guides.
  • Where required, we conduct a balancing test to ensure that our legitimate interests do not override your fundamental rights and freedoms.
• Compliance with legal obligations:
  • We may process and retain certain information where necessary to comply with applicable laws, regulatory requirements, orders from competent authorities, or obligations under consumer protection and privacy laws (for example, keeping records of consent and complaints).

Purpose of Processing

Observe: As a review-focused site, our purposes centre on providing and improving informational content, running affiliate relationships, ensuring security, and fulfilling user requests.

Expand: These purposes must be clearly linked to distinct processing activities and data categories, allowing users to understand why their data is used and how this aligns with Australian privacy principles and broader international standards.

Reflect: We use personal data collected through winward-au.com for the following purposes:

• Providing and operating the website:
  • To display and manage reviews, guides, comparison tables, and related gambling-industry content;
  • To respond to inquiries received via email or contact forms and to provide user support related to this site.
• Improving content and user experience:
  • To analyse how visitors navigate and engage with Winward content, helping us identify popular topics, usability issues, and areas for improvement;
  • To run A/B tests or similar experiments aimed at optimising page layout, navigation, and content relevance.
• Marketing and communications:
  • To send newsletters, promotional messages, or updates about changes to this site or its content, where you have explicitly subscribed and consented;
  • To measure and attribute the effectiveness of campaigns, banners, and affiliate links leading to external Winward Casino domains or related brands.
• Analytics and statistics:
  • To compile aggregated statistics about website traffic, referral sources, conversion rates, and other metrics relevant to the operation of an informational gambling review site;
  • To generate anonymous or pseudonymised reports for internal analysis and for our affiliate or advertising partners.
• Security, fraud prevention, and legal protection:
  • To monitor for, detect, and mitigate suspicious activity, cyber-attacks, and misuse of our services;
  • To establish, exercise, or defend legal claims, and to cooperate with lawful requests from regulators or law enforcement, including ACMA or other competent authorities where applicable.

Disclosure & Sharing

Observe: A review site like Winward may share data with technical service providers, analytics platforms, and affiliate partners and may be required to cooperate with regulators.

Expand: Users need clarity regarding each category of recipient, the type of data shared, and the safeguards applied, particularly in the gambling context where regulators such as ACMA actively monitor offshore operators.

Reflect: We disclose personal data only where necessary and subject to contractual and legal safeguards.

• Technical and hosting service providers:
  • We may share personal data with hosting providers, content delivery networks (CDNs), security services, email delivery platforms, and analytics providers that support the operation of winward-au.com.
  • These providers process data on our instructions and are bound by confidentiality and data protection obligations.
• Analytics and advertising partners:
  • We may use third-party analytics tools and, where applicable, advertising networks that collect or receive technical and usage data via cookies or similar technologies.
  • Where marketing cookies or tracking require consent, data will only be shared with these partners once you have provided such consent via a consent mechanism (if available) or your browser settings.
• Affiliate and casino partners:
  • When you click a link or banner to an external Winward Casino domain or a related affiliate offer, certain tracking parameters (such as our affiliate ID, campaign ID, or click reference) may be transmitted to the destination site to attribute referrals.
  • These partners act as independent controllers of your personal data once you leave winward-au.com; their processing is governed by their own privacy policies.
• Regulators, authorities, and legal processes:
  • We may disclose log data, communication records, or other relevant information to law enforcement agencies, courts, or regulatory bodies (including ACMA or international equivalents) where required by law, a valid legal request, or to protect our legal rights.
• Corporate transactions:
  • In the event of a merger, acquisition, sale of assets, or restructuring involving this review site, personal data may be transferred to the acquiring or successor entity subject to continued protection consistent with this Privacy Policy.

International Transfers

Observe: Our hosting, analytics, and affiliate arrangements may involve transfers of data outside Australia, including to jurisdictions with different privacy standards.

Expand: To align with global best practice (e.g. GDPR) and provide transparency, we must describe the destinations and safeguards used, even where specific frameworks like the former EU - US Privacy Shield have evolved into new arrangements.

Reflect: We implement appropriate safeguards to protect your data during any international transfer.

• Possible destinations:
  • Data may be processed in Australia and other countries, including but not limited to EU/EEA member states, the United Kingdom, the United States, and other locations where our service providers and partners maintain servers or operations.
• Safeguards for cross-border transfers:
  • Where data is transferred from the EU/EEA or the UK to a country without an adequacy decision, we aim to rely on appropriate safeguards such as:
    • Standard Contractual Clauses (SCCs) approved by the European Commission or UK authorities, supplemented where necessary by additional technical and organisational measures;
    • Contractual data protection clauses requiring partners to maintain security and confidentiality standards comparable to those applicable in the origin jurisdiction.
• User responsibilities:
  • By using winward-au.com, you acknowledge that data may be processed and stored in jurisdictions other than your own, where privacy laws may differ, but we will take reasonable steps to maintain an adequate level of protection consistent with this Privacy Policy.

Data Retention

Observe: Different data categories require different retention periods, balancing operational needs and legal obligations against data minimisation principles.

Expand: We must set clear retention guidelines for logs, contact data, analytics, and consent records, while allowing for extension where needed to resolve disputes or comply with statutory requirements.

Reflect: We retain personal data only for as long as reasonably necessary for the purposes described in this Policy or as required by law.

• Contact and communication data:
  • Emails and form submissions are generally retained for up to 5 years from the date of our last interaction, to allow for follow-up queries, complaint handling, and legal defence.
• Technical and log data:
  • Standard web server logs and security logs are typically retained for 6 to 24 months, depending on the sensitivity and necessity, primarily for security, troubleshooting, and abuse detection.
• Analytics and behavioural data:
  • Aggregated analytics data may be retained for up to 5 years, but where possible we use anonymisation or pseudonymisation to reduce privacy impact.
• Marketing and consent records:
  • Subscription and consent records (including opt-in and opt-out logs) may be kept for up to 5 years after you unsubscribe or withdraw consent, to prove compliance with consent requirements.
• Criteria for deletion:
  • Data is deleted or irreversibly anonymised when:
    • The retention period expires;
    • It is no longer necessary for the purpose for which it was collected;
    • We are legally required to erase it, or your valid deletion request is granted.
• Exceptions:
  • We may retain data for a longer period where necessary to establish, exercise, or defend legal claims, or to comply with statutory or regulatory requirements.

Your Rights

Observe: Users may come from jurisdictions influenced by the EU General Data Protection Regulation (GDPR) and Mexican privacy law frameworks (e.g. the Federal Law on Protection of Personal Data Held by Private Parties - LFPDPPP). We must align with these standards where applicable, while recognising that Winward is an informational site focusing on Australia.

Expand: Rights should include access, rectification, erasure, restriction, objection, portability, and withdrawal of consent, along with clear, practical instructions for exercising them and reasonable timelines.

Reflect: Subject to applicable law, you may have the following rights in relation to personal data we process via winward-au.com:

Access, Correction, and Deletion

• Right of access: You can request confirmation of whether we process your personal data and obtain a copy of such data, along with information about how it is used.
• Right to rectification: You can ask us to correct inaccurate or incomplete personal data we hold about you.
• Right to erasure ("right to be forgotten"): You can 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 processing was based on consent) and there is no other legal ground;
  • You have objected to processing and there are no overriding legitimate grounds; or
  • The data has been unlawfully processed.

Restriction, Objection, and Portability

• Right to restrict processing: You may request that we temporarily suspend processing of your data while we address a dispute over its accuracy, lawfulness, or our legitimate interests.
• Right to object: You may object to processing based on our legitimate interests, including profiling related to such interests. We will stop processing unless we demonstrate compelling legitimate grounds or need the data to establish, exercise, or defend legal claims.
• Right to data portability: Where processing is based on consent or contract and carried out by automated means, you may request a structured, commonly used, and machine-readable copy of your personal data, and ask us to transmit it to another controller where technically feasible.

Marketing and Consent Management

• Withdrawal of consent: Where processing (such as certain marketing communications or non-essential cookies) is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing undertaken before withdrawal.
• Direct marketing: You may opt out of marketing emails at any time by using the unsubscribe link in the message or by contacting us at [email protected].

Procedures, Timeframes, and Cost

• How to exercise your rights: Please send a clear written request to [email protected], specifying:
  • Your identity (we may request additional information to verify you);
  • The right(s) you wish to exercise; and
  • Relevant details to help us locate your data (e.g. email address used to contact us, approximate dates of interaction).
• Response time: We aim to respond to all valid requests within 30 days of receipt. This period may be extended by a further 30 days for complex or numerous requests, in which case we will inform you of the extension and reasons.
• Fees: We ordinarily process requests free of charge. However, where permitted by law, we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded, excessive, or repetitive.

Note on Mexican Privacy Law

• To the extent that Mexican privacy law (such as LFPDPPP) applies, you may have ARCO rights (Access, Rectification, Cancellation, and Opposition) similar to those described above. We will endeavour to handle such requests in accordance with both applicable Mexican regulations and the standards outlined in this Policy, where compatible.

Cookies & Tracking Technologies

Observe: Cookies are a central element of analytics and affiliate tracking for a review site, and users must be informed about their types, purposes, and control options.

Expand: We distinguish between essential and non-essential cookies, including third-party analytics or advertising tools, and offer guidance on how to manage them.

Reflect: By using winward-au.com, you consent to the use of cookies as described below, subject to any choices you make via browser or site-specific settings.

Types of Cookies Used

• Session cookies: Temporary cookies that are stored on your device only for the duration of your visit and are deleted when you close your browser. They support core functionality, such as page navigation and security features.
• Persistent cookies: Cookies that remain on your device for a specified period or until you delete them. They may remember your preferences, language settings, or previous interactions with this site.
• First-party cookies: Cookies set directly by winward-au.com to support website functionality and basic analytics.
• Third-party cookies: Cookies set by external service providers (e.g. analytics platforms, affiliate tracking systems, or advertising networks) when you access our pages or click outbound links.

Purposes of Cookies

• Strictly necessary / functional cookies:
  • Required for the proper functioning of the site, such as maintaining sessions, security features, and load balancing.
• Analytics and performance cookies:
  • Used to collect anonymised or pseudonymised information about how visitors use the site, including pages visited, time spent, and any errors encountered, enabling us to improve performance and user experience.
• Advertising and affiliate cookies:
  • Used to track when users click on links or banners pointing to external Winward Casino domains or other partners, to attribute referrals and measure campaign effectiveness.

Managing Cookies

• Browser settings: Most web browsers allow you to:
  • Block all cookies;
  • Block cookies from specific sites;
  • Delete existing cookies; or
  • Receive notifications before a cookie is stored.
  Please refer to your browser's help section for detailed instructions.
• Site-specific tools: Where available, we may provide an on-site cookie banner or preferences tool that allows you to accept or reject certain categories of non-essential cookies.
• Consequences of disabling cookies: Blocking or deleting cookies may affect your ability to use some features of winward-au.com or may result in reduced functionality and performance.

Data Security

Observe: As a site that may handle user contact information and behavioural data in a sensitive industry, robust security measures are essential.

Expand: This includes encryption, access control, audits, staff training, and incident response aligned where possible with recognised security standards.

Reflect: While no system is completely secure, we implement appropriate technical and organisational measures to protect your personal data.

• Encryption:
  • We aim to protect data in transit using industry-standard Transport Layer Security (TLS) protocols (TLS 1.2 or higher), as implemented by our hosting and service providers.
  • Where appropriate, data at rest may be encrypted or stored in secure environments managed by reputable hosting providers.
• Access controls:
  • Access to personal data is restricted to authorised personnel or service providers who require it to fulfil their duties and are bound by confidentiality obligations.
  • Authentication mechanisms (including, where feasible, multi-factor authentication) are used to protect administrative access to systems.
• Security monitoring and audits:
  • We perform periodic reviews of our technical and organisational measures and rely on hosting and infrastructure providers who maintain robust security controls and may hold certifications such as ISO 27001 or SOC 2, where applicable.
• Staff awareness and procedures:
  • Individuals with access to user data are informed of privacy and security obligations and are required to follow internal procedures for secure handling of information.
• Incident response:
  • In the event of a suspected personal data breach, we will investigate promptly, take appropriate remedial steps, and, where required by law, notify affected individuals and relevant authorities within applicable timeframes.

Complaints & Contacts

Observe: Users must have accessible channels to raise questions or complaints, and information about escalation to supervisory authorities, including those in the EU or Mexico where relevant.

Expand: A clear procedure with indicative timelines enhances trust and compliance with international best practice.

Reflect: We provide the following mechanisms for contacting us and pursuing complaints about our handling of personal data on winward-au.com.

Contacting Us

• Email: [email protected] (primary channel for privacy enquiries, access requests, and complaints).
• Online forms: Where a contact or feedback form is available on this site, submissions will be sent to our support address or processed by our service providers on our behalf.
• Postal address: A specific mailing address is not currently specified; we encourage electronic contact for prompt handling of privacy matters.

Complaint Procedure

1. Submission: Send your complaint or concern in writing to [email protected], describing:
   • The nature of your concern (e.g. access request delay, suspected unauthorised use of data);
   • Relevant dates and any supporting documentation; and
   • What outcome you seek (e.g. correction, deletion, clarification).
2. Acknowledgement: We will aim to acknowledge receipt of your complaint within 7 business days.
3. Investigation: We will review your complaint, gather relevant information, and, where necessary, liaise with our service providers.
4. Response: We aim to provide a substantive response within 30 days of receiving your complaint. If more time is required due to complexity, we will inform you of the delay and expected timeframe.
5. Further steps: If you are not satisfied with our response, you may seek further review or escalate the matter to a relevant supervisory authority.

Escalation to Supervisory Authorities

• Australia: You may contact the Office of the Australian Information Commissioner (OAIC) regarding concerns about our handling of personal information:
  • Website: https://www.oaic.gov.au
• Mexico: Where Mexican data protection law applies, you may contact the National Institute for Transparency, Access to Information and Personal Data Protection (INAI):
  • Website: https://www.inai.org.mx
• European Union / EEA: If you are located in the EU/EEA, you may have the right to lodge a complaint with your local data protection authority. Contact details are available at:
  • https://edpb.europa.eu/about-edpb/about-edpb/members_en

Please note that these authorities act independently of Winward; we encourage you to contact us first so that we can attempt to resolve your concern directly.

Updates

Observe: Privacy practices and legal requirements evolve. Users must be informed about how changes to this Policy are communicated, including timing, notification channels, and options for objection.

Expand: A clear update process with version control and advance notice (where material changes occur) supports transparency and compliance.

Reflect: We may update this Privacy Policy from time to time to reflect changes in law, technology, or our operations.

Notification of Changes

• Publication on site: The current version of the Privacy Policy will always be available on winward-au.com, with a "Last updated" date indicated at the end of the document.
• Direct notifications: For material changes that significantly affect how we process your personal data, we will, where feasible:
  • Send an email notification to users who have provided an email address and whose data is materially impacted; and/or
  • Display a prominent notice or banner on the website, or issue an alert via user-accessible areas (such as an account dashboard, if such features are introduced).

Advance Notice and User Options

• Advance notice: For significant changes that would broaden our processing activities or introduce new types of personal data usage, we will aim to provide at least 30 days' advance notice before the changes take effect, unless immediate implementation is required by law or security reasons.
• User choices: If you do not agree with the updated Privacy Policy, you should:
  • Discontinue using winward-au.com; and
  • Exercise any available rights (e.g. deletion, restriction) by contacting [email protected].

Last updated: January 2026