Privacy Policy
Who We Are
OBSERVE: The Site is a gambling-related review and informational portal targeting Australian users and referring to the brand "Frumzi" operated offshore. The operator details provided relate to the underlying gambling operator, while the Site itself functions as an informational and affiliate platform only.
EXPAND: To ensure transparency, we identify both the corporate operator behind the Frumzi brand and the primary contact channels for privacy-related queries. As the gambling services are operated from Curaçao by a licensed company, data may be processed and stored outside Australia.
REFLECT: The following information is provided to clearly indicate the responsible entities, corporate seat, and how you can contact us regarding privacy matters.
Operator of gambling services related to the Frumzi brand
- Company name: Rabidi N.V. (a private limited liability company)
- Registered / legal address: Scharlooweg 39, Willemstad, Curaçao
- Operator jurisdiction: Curaçao
- Online gambling licence: 8048/JAZ issued by Antillephone N.V., Curaçao, valid until at least 31 December 2026
Site and review service
- Site name: Frumzi (review and informational service only)
- Domain: https://frumzi-aussie.com
- Nature of service: independent review, comparison, and informational content about Frumzi and other gambling services; the Site itself does not provide real-money gambling services or process player wagers.
Contact for privacy and data protection matters
- Data protection contact / DPO function: Data Protection Department, Frumzi
- Email (primary for privacy): [email protected]
- Email (support-related queries that may include privacy matters): [email protected]
- Postal contact for the operator: Rabidi N.V., Scharlooweg 39, Willemstad, Curaçao
Regional compliance note: The Site targets users located in Australia for informational purposes only. The underlying gambling operator is offshore and subject to Curaçao law. Nothing in this Privacy Policy should be interpreted as indicating that the Frumzi gambling services are licensed in Australia or lawfully targeted at Australian residents.
What Personal Data We Collect
OBSERVE: Visitors may browse the Site, subscribe to communications, or follow links to third-party gambling platforms. During these activities, a range of personal, technical, and behavioural data can be collected directly or via cookies and third-party tools.
EXPAND: To comply with privacy principles, we categorise the information we collect and explain whether collection is mandatory or optional, and whether it is collected by us as the Site operator or by third-party gambling or payment providers.
REFLECT: The following categories describe the data that may be processed in connection with your use of Frumzi.
1. Identification and contact data
- Data types: full name, email address, telephone number (if provided), country or region of residence, communication preferences.
- Source: provided directly by you when:
- subscribing to newsletters or marketing communications;
- sending enquiries to [email protected] or [email protected];
- participating in promotions or surveys run via the Site.
2. Technical and usage data
- Data types: IP address, approximate geolocation (derived from IP), device type, operating system, browser type and version, language settings, referrer URL, access times, and pages viewed.
- Source: collected automatically via server logs, analytics tools, and cookies when you access the Site.
3. Behavioural and interaction data
- Data types: click paths, time spent on pages, scroll depth, links clicked (including outbound partner links), interactions with banners, and preferences inferred from your browsing behaviour (e.g., game type interest).
- Source: collected via cookies, pixels, tracking URLs, and third-party analytics/affiliate platforms.
4. Payment and transaction-related data
- On the Site: The Site does not itself process payments or banking details for gambling activity.
- Via third-party operators: If you register or deposit with the Frumzi operator or other gambling sites referenced on Frumzi, those operators may collect:
- payment method details (e.g., card type, masked card number, e-wallet details);
- transaction identifiers, deposit and withdrawal amounts;
- currency and payment provider identifiers.
5. Gambling and preference data (via linked operators)
- Data types: betting and game history, win/loss records, bonus usage, session time, responsible gambling limits, and related behavioural metrics.
- Source: collected and processed by third-party gambling operators (such as Frumzi at casino-frumzi.com) and may be shared with us in aggregated or pseudonymised form for analytics and affiliate reporting.
6. Cookies and similar technologies
- Data types: unique cookie identifiers, advertising IDs, device identifiers, session tokens, and similar data enabling recognition of your browser or device.
- Source: set by us or by third parties (e.g., analytics and advertising networks) when you visit or interact with the Site.
Regional compliance note: While Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) apply primarily to "personal information" about identified or reasonably identifiable individuals, we treat technical identifiers and behavioural data as personal information where they can be linked or combined to identify you.
Legal Basis for Processing
OBSERVE: The Site engages in multiple types of processing, including operation of the Site, analytics, marketing, and facilitation of affiliate relationships with third-party gambling operators. Different legal bases may apply to different processing activities depending on the nature of the data and your interaction with the Site.
EXPAND: Although the primary regulatory frameworks for the operator are Curaçao law and, where applicable, the laws of users' jurisdictions, we align our practices with widely recognised principles from the EU General Data Protection Regulation (GDPR) and comparable regimes, in addition to Australian Privacy Principles, as a matter of best practice for international users.
REFLECT: The principal legal bases upon which we process personal information are set out below.
- Consent
- We rely on your explicit consent when:
- you sign up for newsletters or marketing materials;
- you allow non-essential cookies (e.g., advertising, profiling, or advanced analytics cookies);
- a third-party operator or partner shares certain marketing-related information about your interactions with its services, subject to your separate consent there.
- You may withdraw your consent at any time (see "Your Rights" below), without affecting the lawfulness of processing based on consent before its withdrawal.
- We rely on your explicit consent when:
- Contract performance and pre-contract steps
- We process your information when necessary to:
- provide you with requested information about casinos, bonuses, or games;
- maintain your subscriptions or registered preferences for communications or comparison tools;
- facilitate redirection to third-party operators (e.g., correctly attributing referral codes or bonus eligibility).
- We process your information when necessary to:
- Legitimate interests
- We may process personal information where this is necessary for our legitimate business interests, provided these are not overridden by your rights and interests, including:
- running, maintaining, and securing the Site;
- conducting analytics to understand how our content is used and to improve it;
- preventing fraud, abuse, or misuse of affiliate systems and bonuses;
- enforcing our terms and defending our legal rights, including cooperation with law enforcement where appropriate.
- We may process personal information where this is necessary for our legitimate business interests, provided these are not overridden by your rights and interests, including:
- Compliance with legal obligations
- We may process and retain certain data to:
- comply with applicable record-keeping obligations under tax, corporate, and gambling-related regulations;
- respond to lawful requests from regulators or law enforcement authorities;
- support third-party operators' compliance with know-your-customer (KYC), anti-money laundering (AML), and responsible gambling requirements, where we receive related information.
- We may process and retain certain data to:
Regional compliance note: For Australian users, our handling of personal information is designed to be consistent with the APPs, including requirements around collection notices, use, disclosure, and cross-border transfer under APP 8. For users from the EU/EEA or jurisdictions with GDPR-style laws, we apply equivalent safeguards and rights as described in this policy.
Purpose of Processing
OBSERVE: Personal, technical, and behavioural data are used to operate the Site, to provide and improve content, and to support affiliate relationships with third-party gambling operators.
EXPAND: To maintain transparency, we map each key category of purposes to typical processing operations and data categories.
REFLECT: We use your personal information solely for the purposes described below, or for closely related compatible purposes.
- Provision and operation of the Site and services
- Displaying pages, reviews, rankings, and bonus information;
- Processing your enquiries and providing support responses;
- Managing subscriptions to newsletters or alerts.
- Improvement of content and user experience
- Analysing how visitors use the Site to improve structure, navigation, and content relevance;
- Testing new features, layouts, and tools;
- Aggregating statistics to understand market trends and user preferences (for example, which game categories are most popular among Australian visitors).
- Marketing and communications
- Sending you newsletters, promotional messages, bonus alerts, and product updates (subject to your consent where required);
- Personalising marketing content based on your preferences and past interactions, where allowed by law;
- Measuring the effectiveness of email campaigns and promotional materials.
- Analytics, measurement, and affiliate attribution
- Tracking referrals to third-party operators for accurate commission and bonus allocation;
- Conducting performance analysis on campaigns, banners, and outbound links;
- Creating aggregated reports that may be shared with partners in non-identifiable form.
- Fraud prevention, security, and compliance
- Monitoring for suspicious patterns (e.g., repeated sign-ups abusing bonuses, automated scripts);
- Protecting the integrity and security of our systems and partner programs;
- Cooperating with lawful requests from authorities and complying with applicable regulations.
Regional compliance note: These purposes align with recognised lawful uses of personal information under Australian Privacy Principles and GDPR-style frameworks, including for the primary purpose of collection and reasonably expected related secondary purposes.
Disclosure & Sharing
OBSERVE: Personal information may be shared internally and externally to operate the Site, provide services, and comply with legal duties.
EXPAND: We distinguish between categories of recipients, including service providers, gambling operators, regulators, and advertising partners, and highlight the safeguards applied.
REFLECT: We only disclose personal information where this is lawful, proportionate, and subject to appropriate contractual and technical protections.
- Affiliated gambling operators and partners
- We may share limited data (such as anonymised or pseudonymised identifiers, referral parameters, and aggregated statistics) with:
- Rabidi N.V. (operator of the Frumzi brand at casino-frumzi.com);
- other licensed gambling operators featured on the Site;
- affiliate networks managing relationships between us and multiple operators.
- This information is typically used to:
- attribute referrals and calculate commissions;
- verify bonus eligibility or campaign performance;
- ensure compliance with bonus and marketing rules.
- We may share limited data (such as anonymised or pseudonymised identifiers, referral parameters, and aggregated statistics) with:
- Service providers and technical vendors
- We engage third-party providers to support:
- website hosting and content delivery;
- email and marketing automation;
- analytics, error monitoring, and performance measurement;
- security, anti-fraud, and bot-detection tools.
- These processors may have access to personal information strictly to perform services on our behalf under contractual obligations of confidentiality and data protection.
- We engage third-party providers to support:
- Regulators, law enforcement, and legal advisers
- We may disclose information where required or permitted by law, including:
- to competent regulators or authorities (for example, Curaçao regulators overseeing licence 8048/JAZ, or Australian authorities such as the Australian Communications and Media Authority in connection with offshore site blocking activities);
- to comply with court orders, subpoenas, or lawful investigations;
- to our legal, tax, or compliance advisers for the purpose of obtaining professional advice.
- We may disclose information where required or permitted by law, including:
- Advertising and analytics networks
- With your consent where required, we may allow third-party advertising and analytics providers to:
- place cookies or pixels on the Site;
- collect information about your device, browsing, and interactions;
- serve personalised or interest-based advertising on our Site or on third-party sites.
- Such providers act as independent controllers of the data they collect and process, under their own privacy policies.
- With your consent where required, we may allow third-party advertising and analytics providers to:
- Corporate transactions
- In the event of a merger, acquisition, restructuring, or sale of assets involving our Site or affiliate business, personal information may be transferred to the relevant third parties, subject to continued protection consistent with this Privacy Policy.
Regional compliance note: For Australian users, we take reasonable steps to ensure that overseas recipients of personal information do not breach the APPs in relation to that information, consistent with APP 8, unless an exception applies.
International Transfers
OBSERVE: The Site and affiliated services are operated from, and in collaboration with, entities located outside Australia, including in Curaçao and other jurisdictions used by our hosting and analytics providers.
EXPAND: Cross-border transfers occur whenever your personal information is stored on servers or accessed by personnel or processors outside your home jurisdiction.
REFLECT: We implement contractual, organisational, and technical safeguards aimed at providing a level of protection comparable to that of leading international privacy regimes.
- Destinations of data transfers
- Curaçao - for the operations and regulatory oversight of Rabidi N.V. and related gambling services;
- European Economic Area (EEA) and/or United Kingdom - for certain hosting, analytics, and marketing services;
- United States and other countries - for cloud services, content delivery, security tools, and email service providers.
- Safeguards for international transfers
- Use of data processing agreements and, where applicable, standard contractual clauses or equivalent mechanisms recognised under GDPR-style frameworks;
- Obligations on recipients to maintain appropriate security and confidentiality measures;
- Limitation of transfers to what is necessary for the purposes described in this Privacy Policy.
Regional compliance note: For Australian users, we will take reasonable steps to ensure that overseas recipients handle personal information consistently with the APPs or are otherwise subject to comparable legal protections, except where you expressly consent to a specific transfer after being informed of potential risks.
Data Retention
OBSERVE: Personal information must not be kept longer than necessary for the purposes for which it is processed.
EXPAND: Different categories of data require different retention periods under legal, contractual, and operational considerations.
REFLECT: We apply defined retention criteria and securely delete or anonymise data when it is no longer needed.
- Identification and contact data
- Data provided for enquiries is typically retained for up to 3 years from the date of our last meaningful interaction, to manage follow-up and potential disputes.
- Newsletter and marketing subscription data is retained until you unsubscribe or until it has been inactive for 2 years, after which it may be anonymised for analytics.
- Technical, usage, and behavioural data
- Server logs and security-related records are typically retained for 6 to 24 months, unless a longer period is required for security or legal reasons.
- Analytics data may be retained in identifiable form for up to 24 months, after which it may be aggregated or anonymised.
- Affiliate and transactional data (non-payment)
- Referral-related identifiers and attribution records may be kept for up to 5 years to handle accounting, disputes, and regulatory requirements.
- Third-party operator records
- Any gambling account, payment, or KYC data you provide directly to Frumzi or other operators is retained according to their own policies and legal obligations. We may receive only aggregated or pseudonymised data, which can be retained for longer periods as it is no longer personally identifiable.
- Legal and regulatory retention
- We may retain information necessary for legal claims, audits, and compliance (including with gambling and financial regulations) for up to the maximum limitation period under applicable law, generally not exceeding 7 years from the relevant event.
Deletion criteria: We delete or irreversibly anonymise personal information when:
- it is no longer necessary for the purposes for which it was collected;
- you successfully exercise your right to deletion (where applicable);
- we are no longer legally required to keep it.
Your Rights
OBSERVE: Individuals have various rights concerning the personal information that organisations hold about them. While the specific scope of rights can vary by jurisdiction, we broadly align our practices with GDPR-style and comparable regimes.
EXPAND: Mexican data protection law references in the specification are treated as guidance for strong international standards. Although our main focus is Australian users and offshore operations, we endeavour to provide a consistent rights framework, particularly where users are located in jurisdictions such as the EU/EEA or Mexico that provide strong statutory rights.
REFLECT: The rights below may be subject to legal limitations and exceptions, but we will always consider and respond to your request.
1. Right of access
- You may request confirmation as to whether we process personal information about you and, where applicable, receive a copy of such information together with information about the processing.
2. Right to rectification (correction)
- You may request that inaccurate or incomplete personal information be corrected or updated.
3. Right to deletion (erasure)
- You may request that we delete personal information where:
- it is no longer necessary for the purposes for which it was collected;
- you withdraw consent and there is no other legal basis for processing;
- you validly object to processing (see below);
- the data has been processed unlawfully or must be deleted to comply with a legal obligation.
- We may need to retain certain data despite your request where required by law or where necessary to establish, exercise, or defend legal claims.
4. Right to restriction of processing
- You may request that we restrict the processing of your personal information where:
- you contest its accuracy (for a period enabling us to verify it);
- the processing is unlawful and you prefer restriction to deletion;
- we no longer need the data but you require it for legal claims;
- you have objected to processing pending verification of our legitimate grounds.
5. Right to object
- You may object at any time, on grounds relating to your particular situation, to processing based on our legitimate interests, including profiling.
- We will stop processing unless we demonstrate compelling legitimate grounds which override your interests, rights, and freedoms, or where processing is required for legal claims.
- You have an unconditional right to object to direct marketing and associated profiling. In such cases, we will cease processing your data for marketing purposes.
6. Right to data portability
- Where processing is based on your consent or on a contract and carried out by automated means, you may request to receive your personal information in a structured, commonly used, and machine-readable format and to have it transmitted to another controller where technically feasible.
7. Right to withdraw consent
- Where we rely on your consent (for example, for email marketing or non-essential cookies), you may withdraw that consent at any time, without affecting the lawfulness of prior processing.
Procedures, timeframes, and cost
- How to exercise your rights: Contact us at [email protected] or [email protected], clearly stating:
- your full name;
- contact details;
- the specific right(s) you wish to exercise;
- any relevant context (e.g., newsletter subscription, affiliate link usage).
- Verification: We may request additional information to verify your identity before acting on your request, to protect your privacy and security.
- Response time: We aim to respond to all valid requests within 30 days of receipt. In complex cases, this period may be extended by a further 30 days, in which case we will inform you of the extension and reasons.
- Fees: Requests are generally handled free of charge. We may charge a reasonable fee or refuse to act on manifestly unfounded or excessive requests, particularly where they are repetitive.
Note for Mexican and EU/EEA users: Where local data protection laws in your country of residence provide additional or more stringent rights, we will seek to respect those rights to the extent applicable to our operations, even where our primary legal obligations are under Curaçao and Australian frameworks.
Cookies & Tracking Technologies
OBSERVE: The Site uses cookies and similar tracking technologies to enable core functionality, analyse traffic, and support marketing and affiliate activities.
EXPAND: Cookies can be first-party (set by us) or third-party (set by external providers) and may be session-based or persistent.
REFLECT: We provide you with clear information about the types of cookies used, their purposes, and how you can manage your preferences.
Types of cookies we use
- Strictly necessary / functional cookies
- Purpose: Enable basic Site operations such as page navigation, access to secure areas, and saving of minimal preferences (e.g., language settings).
- Duration: Session or short-term persistent.
- These cookies are essential for the Site to function properly and cannot be switched off in our systems, although you can block them via your browser settings (which may affect Site performance).
- Analytics and performance cookies
- Purpose: Collect aggregated information about how visitors use the Site (pages visited, time spent, error messages) to improve performance and user experience.
- Duration: Session or persistent (often up to 24 months).
- These may be provided by third-party analytics services and may involve generating statistics and trends.
- Advertising and affiliate tracking cookies
- Purpose: Track referrals to third-party gambling operators, measure the performance of marketing campaigns, and sometimes support interest-based advertising.
- Duration: Persistent cookies typically lasting from a few days to several months.
- These may be set by affiliate networks, advertising partners, or the operators themselves when you click on an outbound link.
Managing cookies
- You may manage or disable cookies through your browser settings by following the instructions provided by your browser (e.g., Chrome, Firefox, Safari, Edge).
- Some browsers and devices provide additional tools to manage tracking technologies and advertising identifiers.
- Disabling certain cookies may affect the functionality and user experience of the Site.
Regional compliance note: Where required by applicable law, we will request your consent before setting non-essential cookies and will provide you with a mechanism to update or withdraw your cookie preferences.
Data Security
OBSERVE: Protecting personal information against unauthorised access, alteration, disclosure, or destruction is of critical importance.
EXPAND: We implement a combination of technical, organisational, and physical measures reflecting industry best practices and international standards.
REFLECT: While no system can be guaranteed as completely secure, we endeavour to maintain a security posture appropriate to the nature and volume of data processed.
- Technical measures
- Use of TLS 1.2 or higher to encrypt data in transit between your browser and our servers;
- Encryption of sensitive data at rest where technically appropriate;
- Regular updates and patching of servers, frameworks, and third-party components;
- Firewalls, access control lists, and intrusion detection measures to protect infrastructure.
- Access controls and authentication
- Role-based access controls ensuring only authorised personnel can access personal information on a need-to-know basis;
- Use of strong authentication methods (including multi-factor authentication where applicable) for administrative access.
- Organisational and procedural measures
- Internal policies and procedures governing data handling, retention, and security;
- Staff training and awareness programmes addressing privacy, security, and responsible use of data;
- Vendor due diligence to ensure that service providers maintain appropriate security standards (for example, many of our providers adhere to recognised frameworks such as ISO 27001 or SOC 2).
- Incident response
- Logging and monitoring systems designed to detect anomalous activities;
- Documented incident response procedures for investigating, containing, and remediating security events;
- Where required by law, notification to affected individuals and/or relevant authorities in the event of a data breach that is likely to result in a serious risk to individuals' rights and freedoms.
Regional compliance note: Our security practices are designed to meet or exceed expectations under the Australian Privacy Act 1988 (Cth) and APP 11 regarding protection of personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure.
Complaints & Contacts
OBSERVE: Individuals may have questions or complaints about how their personal information is handled.
EXPAND: We provide multiple contact channels and a clear procedure for lodging and escalating complaints, including to relevant supervisory authorities.
REFLECT: We take privacy concerns seriously and commit to addressing them in a timely and transparent manner.
How to contact us
- Primary privacy contact / DPO function:
- Email: [email protected]
- Support contact (including privacy-related issues):
- Email: [email protected]
- Postal contact for the operator:
- Rabidi N.V., Scharlooweg 39, Willemstad, Curaçao
Internal complaint procedure
- Submission: Send your complaint or query via email, clearly marking it as a "Privacy complaint" or "Data protection request". Include:
- your name and preferred contact details;
- a description of your concern, including relevant dates and context;
- any supporting documentation (e.g., copies of emails, screenshots).
- Acknowledgement: We aim to acknowledge receipt of your complaint within 5 business days.
- Investigation: We will investigate your complaint, which may involve contacting you for further information.
- Response: We endeavour to provide a substantive written response within 30 days of receiving your complaint. If the issue is complex or requires more time, we will inform you of the delay and provide an updated timeframe.
- Resolution and follow-up: Where we find that we have not complied with our obligations, we will take appropriate steps to rectify the issue, which may include updating records, changing processes, or offering explanations and apologies.
Escalation to supervisory authorities
If you are not satisfied with our response, or if you prefer not to contact us first, you may have the right to lodge a complaint with a relevant supervisory authority, depending on your location.
- Australia
- Office of the Australian Information Commissioner (OAIC)
- Website: https://www.oaic.gov.au
- Phone (Australia): 1300 363 992
- European Union / EEA
- You may contact your local data protection authority. Contact details for EU/EEA data protection authorities are available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en
- Other jurisdictions (including Mexico)
- If you are located in a jurisdiction with a dedicated data protection authority (for example, Mexico's National Institute for Transparency, Access to Information and Personal Data Protection, INAI), you may have the right to lodge a complaint with that authority in accordance with local law.
Regional compliance note: Nothing in this section limits any rights you may have under the laws applicable to you to seek judicial or administrative remedies.
Updates
OBSERVE: Privacy and data protection laws, as well as our services and processing activities, may evolve over time.
EXPAND: It is therefore necessary to update this Privacy Policy periodically.
REFLECT: We commit to providing clear notice of material changes and to maintaining a transparent record of significant updates.
- Version control and effective date
- This Privacy Policy is identified as version 4.0 for Frumzi.
- Last updated: January 2026.
- Notification of changes
- Non-material updates (for example, clarifications or minor editorial changes) may be posted on the Site without specific notice, with the "Last updated" date revised accordingly.
- For material changes that significantly affect how we process your personal information or your rights, we will:
- provide prominent notice on the Site (e.g., a banner or pop-up); and/or
- notify you via email where we hold your address and the change is relevant to your relationship with us.
- Where required by law or where the change is substantial, we will provide notice at least 30 days in advance of the effective date of the changes.
- Your options
- If you do not agree with the updated Privacy Policy, you should discontinue use of the Site and, where applicable, unsubscribe from our communications.
- Continued use of the Site after the effective date of an updated Privacy Policy will constitute your acceptance of the changes, to the extent permitted by law.
You are encouraged to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your personal information in connection with Frumzi and the Site operated at frumzi-aussie.com.