Privacy Policy

Gaming Manager · a Hospitality Services NZ app
Last updated: 16 July 2026

This Privacy Policy explains how the Gaming Manager application ("the app") handles information. The app is published by Hospitality Services NZ ("we", "us"). It is designed for gaming venues operating gaming machines (in New Zealand, Class 4 venues). By using the app you agree to this policy.

Summary

Gaming Manager is a self-contained compliance and shift tool — self-exclusion register, ID / age checks, responsible-gambling logging, jackpot and large-payout records, machine fault logs, cash & floats, and shift reports. We do not collect, transmit, sell, or share any personal information. Everything you enter stays on the device where you enter it; there is no account and no Hospitality Services NZ server that receives your data.

Information stored on your device

To do its job, the app saves the following locally on your device only (in the browser's local storage):

This data is never uploaded to us or any third party. We have no access to it.

Self-exclusion & exclusion register

The app helps venue staff record excluded gamblers to support host-responsibility and harm-minimisation obligations (in New Zealand, under the Gambling Act 2003 and associated regulations). A record may include the person's name, date of birth, reason (for example a self-exclusion or a venue-issued exclusion under s.310), start and review/expiry, notes and an optional photo. The personal parts of each record are encrypted at rest (AES-256-GCM) and signed by your venue key. This is sensitive personal information — record only what is necessary, keep it accurate, and remove records once no longer required.

These records stay on your device. If you mark a record "shareable", it is flagged so you can share it with other venues or staff you operate; any sharing is carried out by you and under your control. As the venue you are the data controller for these records and responsible for handling them lawfully, under the privacy law that applies to you (see “Which privacy law applies” below) and your local gambling-regulatory obligations (see “Jurisdiction & compliance scope”).

Camera, photos and voice

If you attach a photo, the app uses your camera or photo library only to add that image to a record or report; photos are stored locally and included only in reports you generate. The optional ID scan uses the camera to read a passport or licence and pre-fill a name and date of birth — this happens on your device and the image is not saved or uploaded. The optional voice date-of-birth feature uses your device's speech recognition to fill the DOB fields; spoken audio is handled by your device/browser and is not stored or sent by the app.

Reports you create

When you generate a PDF, use the share sheet, or use the email button, the report is created on your device and shared only by you, to recipients you choose. We are not involved in and do not receive these reports.

Third-party services

The app loads a PDF library, an image-cropping library, a passport text-recognition component, and web fonts from public content-delivery networks (cdnjs and Google Fonts) so it can display and export correctly. These standard requests may expose your device's IP address to those providers as part of normal internet operation. No app data is sent to them; see their own policies for details.

Data retention and deletion

You are in full control. Clear data at any time with the in-app options ("Clear" buttons, "Start new shift", removing an exclusion record, or clearing lists). Exclusion records auto-delete at their review/expiry where set. Removing the app or clearing the browser's site data permanently deletes all stored information from the device.

Security

Gaming Manager requires an access PIN, set the first time the app is used, and supports fingerprint / face unlock on supported installed devices over HTTPS. The app locks on launch and after a period in the background. Because your data never leaves the device, its security also depends on the device itself — we recommend a device passcode or biometric lock. If a PIN is lost, the only reset erases the app's data on that device.

Children

This app is intended for gaming-venue staff and is not directed at children. It should only be used by adults of legal working age.

Which privacy law applies

Hospitality Services NZ is based in New Zealand and follows the Privacy Act 2020. Because the app stores data only on the operator's device and we receive nothing, the operator is the data controller and must comply with the privacy law of their own country. Depending on where the app is used that may include the Privacy Act 2020 (New Zealand), the Privacy Act 1988 (Australia), the UK GDPR and Data Protection Act 2018, the EU GDPR (Spain, Portugal and other EU/EEA countries), PIPEDA and provincial laws such as Québec's Law 25 (Canada), state laws such as the CCPA/CPRA (United States), POPIA (South Africa), the LGPD (Brazil), the LFPDPPP (Mexico), and the data-protection laws of Argentina, Colombia, Chile and Peru. This policy is written to meet the transparency requirements common to these regimes; where local law grants people extra rights (such as access, correction or deletion), the operator is responsible for honouring them.

Jurisdiction & compliance scope

Gaming Manager's compliance features — the self-exclusion / exclusion register, responsible-gambling prompts and host-responsibility logging — are modelled on New Zealand's Gambling Act 2003 and the associated Class 4 / Department of Internal Affairs host-responsibility requirements (including venue-issued exclusions under s.310). Gambling law differs significantly between countries — for example Australia regulates gaming state-by-state, the United Kingdom operates under the Gambling Act 2005 and the Gambling Commission (with the national GAMSTOP self-exclusion scheme), the United States regulates state-by-state and by tribal authority, and other countries have their own licensing, self-exclusion and minimum-age rules. The app does not reshape itself to each country's gambling law and using it does not by itself make an operator compliant outside New Zealand. Operators outside New Zealand must confirm that the app's exclusion and responsible-gambling features fit their local scheme and data-handling duties before relying on them. The in-app country selector sets the legal purchase/entry age and accepted ID types only; it is not a full compliance engine.

Changes to this policy

We may update this policy from time to time. Material changes will be reflected by updating the "Last updated" date above.

Contact

Questions about this policy can be sent to:
Hospitality Services NZ
hospitality.services.nz@gmail.com