Privacy Policy

Last Revised: 1 January 2025

1. Committed To Your Privacy

This Privacy Policy explains how Caligula’s Entertainment Ltd. (“Caligula’s”, “we”, “us”, “our”) collects, uses, discloses and protects personal data when you use www.caligulas.casino or www.caligulas.com and related Services. By using this website, you agree to be bound by the Terms & Conditions, this Privacy Policy, and our Game Rules. If you do not agree with any of these policies, you must not use this site.

For the purposes of Bahamian data protection law, including the Data Protection (Privacy of Personal Information) Act, 2003 (Ch. 324A) (the “Bahamas Data Protection Act”), Caligula’s Entertainment Ltd. is the “data controller” in respect of your personal data.

Our contact details:

Caligula’s Entertainment Ltd.
c/o Vistra Corporate Services P.O. Box N-3924
Marlborough & Queen Street
Nassau, New Providence, The Bahamas
Email: info@caligulas.casino
Phone: +1 (317) 442-1437

We may also process personal data jointly with land-based partners, such as Harrah's Cherokee Casino & Hotel, 777 Casino Drive, Cherokee, NC, USA 28719, where we jointly offer promotions or services.

2. Scope of This Policy

This Privacy Policy applies to personal data we collect:

Through our website www.caligulas.com;
Through any related mobile apps;
When you create and use a player account;
When you visit our land-based casino or participate in linked promotions;
When you contact us or interact with our support or marketing channels.

This Policy does not apply to third-party websites or services that may link to or from our Services.

3. Personal Data We Collect

Depending on how you interact with us, we may collect:

Identity and contact data

Name, date of birth, gender;
Residential and mailing address;
Email address and phone number;
Government-issued identification (e.g., passport, national ID, driver’s licence);
Copies of supporting documents provided for KYC verification.

Account and transactional data

Username, account ID, passwords and security credentials;
Deposit, wager and withdrawal history;
Game play history and session logs;
Loyalty program participation and points;
Records of bonuses and promotional offers.

Financial and payment data

Partial payment card details (tokenized where possible);
Bank account details (for withdrawals or verification);
Transaction identifiers and payment service provider details.

Technical and usage data

IP address, device identifiers, browser type, operating system;
Access times, pages viewed, links clicked;
Geolocation information (e.g., to determine the jurisdiction where you are physically located for gaming availability and legal compliance).

Communications and support

Records of communications with us, including emails, chat logs, and support tickets;
Call recordings where permitted by law and with appropriate notice.

Regulatory and risk data

Information obtained from public sources, sanctions and politically exposed person (PEP) lists;
Information provided by fraud-prevention and identity-verification services.

We may collect data directly from you, automatically through your use of the Services (e.g., cookies), or from third-party providers that assist us with identity verification, fraud prevention, payments and analytics.

4. How We Use Your Personal Data

We use your personal data for the following purposes, to the extent permitted by the Bahamas Data Protection Act and other applicable laws:

Account creation and management
- To register and administer your player account, verify your identity and age, and maintain your account settings.
Provision of gaming and related services
- To enable you to place bets, participate in games, receive results and payouts, and use bonuses and loyalty programs under our licences (including any restricted interactive gaming licence issued under the Gaming Act).
Regulatory compliance and AML/CTF
- To comply with our obligations under the Gaming Act, anti-money laundering, counter-terrorist financing and sanctions laws, including customer due diligence, monitoring transactions, and reporting suspicious activities to competent authorities.
Risk management and fraud prevention
- To prevent, detect and investigate fraud, cheating, money laundering and other prohibited or illegal activities.
Payments
- To process deposits and withdrawals, resolve chargebacks or payment disputes, and maintain financial records.
Customer support and communications
- To respond to your inquiries and complaints, send administrative notifications, and manage your preferences.
Marketing (where permitted)
- To send you marketing communications (e.g., offers, bonuses, newsletters) about our services or partner promotions, where permitted by law and your preferences. You may opt out at any time.
Legal claims and enforcement
- To establish, exercise or defend legal rights; enforce our Terms; and cooperate with regulators, law enforcement and courts where required or permitted by law.
Service improvement and analytics
- To analyze usage patterns, improve our products and services, develop new features, and maintain the security and performance of our systems.

5. Cookies & Tracking Technologies

We use cookies and similar technologies to:

Remember your preferences and settings;
Keep you logged in;
Analyze how visitors use our Services;
Support security and fraud prevention;
Deliver and measure the effectiveness of marketing campaigns.

You can manage cookie preferences through your browser settings and, where available, our on-site cookie controls. Disabling certain cookies may affect the functionality of the Services.

[Add link to a standalone Cookie Policy if you plan to have one.]

6. EU/UK Residents

If you decide to allow residents of the European Economic Area (EEA) or United Kingdom to use your Services, your processing of their personal data may also be subject to the EU/UK General Data Protection Regulation (GDPR). In that case, you should have your counsel adapt this section to identify the relevant legal bases (e.g., contract necessity, legal obligation, legitimate interests, consent).

7. Do We Share Your Personal Data?

We may share your personal data with:

Group companies and affiliates, where necessary for operations, support, risk management or reporting;
Land-based casino partners, such as Harrah's Cherokee Valley River Casino & Hotel, for joint promotions, loyalty programs or shared player benefits (where legally permitted and in accordance with this Policy);
Service providers and processors, including:
- Payment processors and banks;
- Identity verification and KYC providers;
- Fraud-prevention and analytics services;
- Cloud hosting and IT providers;
- Marketing and communications providers (e.g., email platforms).
Regulators and authorities, including the Gaming Board for The Bahamas, financial intelligence units, police and other governmental bodies, where required by the Gaming Act, anti-money laundering and other laws.
Professional advisers, such as lawyers, auditors and consultants;
Other parties in connection with business transactions, such as mergers, acquisitions, reorganizations or asset sales, subject to appropriate safeguards.

We do not sell your personal data as that term may be defined under certain privacy laws. If you later target U.S. states like California with specific statutory rights, your counsel may wish to adjust this language.

8. International Transfers

Your personal data may be transferred to and processed in countries outside The Bahamas, including countries that may not provide the same level of data protection as The Bahamas.

The Bahamas Data Protection Act includes provisions limiting the transfer of personal data outside The Bahamas except where adequate protection is ensured or other specified conditions are satisfied.

Where required by law, we will implement appropriate safeguards for such transfers, which may include:

Contractual protections (e.g., data-processing agreements);
Requiring service providers to meet specific security and privacy standards;
Limiting transfers to jurisdictions recognized as providing adequate protection under applicable law.

9. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Policy, including:

For the duration of your relationship with us;
To comply with the Gaming Act, anti-money laundering and record-keeping obligations (which may require retaining certain records for specified minimum periods);
To resolve disputes and enforce our agreements;
To comply with legal and regulatory requirements.

After the applicable retention period has expired, we will securely delete or anonymize your personal data, unless we are required by law to retain it longer.

10. Your Rights

Under the Bahamas Data Protection Act, individuals generally have rights including:

The right to be informed about the processing of their personal data;
The right to access personal data held about them;
The right to rectification of inaccurate data;
The right, in certain circumstances, to erasure of data or to object to particular processing;
The right to object to processing for direct marketing;
The right to seek redress through the Data Protection Commissioner or the courts.

To exercise your rights, please contact us at privacy@caligulas.com. We may need to verify your identity before fulfilling your request and may be unable to comply where an exemption applies (for example, where disclosure would breach another person’s rights or where we are required by law to retain data).

If you believe we have violated data protection law, you may have the right to complain to the Data Protection Commissioner in The Bahamas or another competent authority.

11. Children’s Privacy

Our Services are not directed to children and we do not knowingly collect personal data from anyone under eighteen (18) years of age. We do not knowingly allow individuals under the minimum legal gambling age in their jurisdiction to open accounts or place wagers.

We also do not knowingly collect personal data from children under 13 years of age, in line with U.S. Children’s Online Privacy Protection Act (COPPA) requirements.

If you believe that a child has provided personal data to us, please contact us immediately so that we can investigate and take appropriate steps, including deletion of such data where required.

12. Security

We implement reasonable technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, taking into account the nature of the data and the risks involved. These measures may include:

Encryption in transit and at rest where appropriate;
Access controls and authentication;
Logging and monitoring;
Regular security assessments and staff training.

No system is completely secure. We cannot guarantee absolute security of your data, but we aim to comply with applicable obligations under Bahamian law and, where relevant, the expectations of regulators such as the U.S. Federal Trade Commission regarding reasonable data security and privacy practices.

13. Third-Party Websites & Services

The Services may contain links to third-party websites, apps or services that are not controlled by us. This Privacy Policy does not apply to such third parties. We are not responsible for the privacy practices of third-party sites and encourage you to review their privacy policies before providing any personal data.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, for example to reflect:

Changes in the Bahamas Data Protection Act or replacement legislation (such as any new Data Protection Act enacted following the Data Protection Bill, 2025);
Changes to the Gaming Act or regulatory guidance;
Evolving guidance from regulators (including the FTC in the United States) about online privacy and data security.

Where required by law, we will notify you of material changes and, if necessary, obtain your consent. Your continued use of the Services after changes take effect indicates your acceptance of the updated Policy.

15. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact: