Summary. TopAussieHub is an entertainment-only games website for Australian players, operated by Extravirgine, a business based in Estonia. We handle personal information in line with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) and, because we are established in the European Union, the GDPR. We only collect what we need, we only use analytics and marketing cookies with your consent, and we never sell your information. You can ask to access or correct your information, opt out of marketing or make a complaint at any time by emailing info@extravirgine.online.
1. Who we are
This website is operated by:
Extravirgine
Juubelitammede tee 16
Saku alevik, Saku vald
Harju maakond, 75501
Estonia
Email: info@extravirgine.online
In this policy, “we”, “us” and “our” mean Extravirgine. For Australian users, this document is our privacy policy for the purposes of APP 1. For the purposes of the GDPR, Extravirgine is the controller of your personal data.
TopAussieHub provides entertainment-only games for adults aged 18 and over. It does not accept payments and does not offer cash-value play, cash-outs or rewards with real-world monetary value, so we do not collect payment or financial information.
2. Personal information we collect
Information you give us
- Contact form: your name, email address, phone number (optional) and the content of your message.
- Game updates (newsletter) form: your name, email address, phone number (optional), comment (optional) and a record of your consent.
- Emails you send us: your email address and anything you choose to include.
Information collected automatically
- Server log data: IP address, date and time of access, pages requested, referring URL, browser type and operating system.
- Cookie preferences: your cookie choices, stored in your browser so we can respect them.
- Analytics data (only with your consent): pages visited, session length, approximate location (country/city level), device and browser details and interaction metrics.
- Referral and campaign data (only with your consent): identifiers that show which campaign or link brought you to the site.
We do not intentionally collect sensitive information (such as health, racial or ethnic origin, political opinions or religious beliefs). Please do not include it in your messages.
3. How we collect personal information
We collect personal information directly from you when you fill in a form or email us, and automatically when you use the website (through server logs and, if you consent, cookies). We do not buy personal information from third parties. If we receive personal information we did not ask for and could not have collected ourselves, we will destroy or de-identify it where lawful and reasonable to do so (APP 4).
4. Anonymity and pseudonymity
You can browse the website and play the games without telling us who you are. You may also contact us using a pseudonym. However, we need a working email address to reply to an enquiry or to send you game updates.
5. Why we collect, use and disclose personal information
We only use personal information for the purpose it was collected for, for a related purpose you would reasonably expect, or as otherwise permitted by law (APP 6). The GDPR requires us to also state the legal basis for each use:
| Purpose | Information | GDPR legal basis |
|---|---|---|
| Running the website securely and keeping it stable | IP address, log data, device and browser data | Legitimate interests — Art. 6(1)(f) |
| Remembering your cookie choices | Cookie preferences | Legal obligation — Art. 6(1)(c); legitimate interests — Art. 6(1)(f) |
| Replying to your enquiries | Name, email, phone (optional), message | Legitimate interests — Art. 6(1)(f) |
| Sending game updates | Name, email, phone (optional), comment, consent record | Consent — Art. 6(1)(a) |
| Website analytics | Usage and device data, cookie identifiers | Consent — Art. 6(1)(a) |
| Referral and campaign measurement | Referral and tracking identifiers | Consent — Art. 6(1)(a) |
| Preventing misuse and enforcing our Terms | IP address, log data | Legitimate interests — Art. 6(1)(f) |
| Meeting legal obligations and handling legal claims | Information as required | Legal obligation — Art. 6(1)(c); legitimate interests — Art. 6(1)(f) |
Where we rely on consent, you can withdraw it at any time. This does not affect anything we did before you withdrew it.
6. Cookies and similar technologies
We only use strictly necessary storage without asking. Analytics cookies (such as Google Analytics) and marketing/referral cookies are only set if you opt in through our cookie banner. Rejecting them is as easy as accepting them, and you can change your choice at any time via Cookie settings, which is also linked in the footer of every page.
If you enable analytics, we use Google Analytics, provided by Google LLC and its affiliates. Google Analytics 4 does not log or store IP addresses. You can also install the Google Analytics opt-out browser add-on. See our Cookie Policy for more detail.
7. Direct marketing
We only send game updates by email if you have expressly agreed to receive them, in line with APP 7, the Spam Act 2003 (Cth) and the GDPR. Every email identifies us as the sender and contains a working unsubscribe link. You can also opt out at any time by emailing info@extravirgine.online, and we will action your request within 5 business days. We do not sell or share your details with others for their marketing.
8. Who we disclose personal information to
We do not sell or rent personal information. We only disclose it where necessary, to:
- our hosting provider, DreamHost, LLC (United States), which hosts the website and stores server logs and form submissions for us;
- our analytics provider (Google), only if you consent;
- email and IT service providers that help us receive and send email and maintain the website;
- referral and campaign-measurement partners, only if you consent;
- professional advisers (such as lawyers and accountants) bound by confidentiality; and
- courts, regulators or law enforcement where required or authorised by law.
Our service providers may only use personal information to provide services to us, under written agreements that require them to protect it.
9. Overseas disclosure
We are based outside Australia, so your personal information will be handled overseas. It is likely to be held or accessed in Estonia and other European Union countries (where we operate) and in the United States (where our hosting and analytics providers are located). Before disclosing personal information overseas, we take reasonable steps to make sure the recipient handles it in line with the APPs (APP 8). This includes contractual protections such as the European Commission’s Standard Contractual Clauses, or relying on the EU–U.S. Data Privacy Framework where the recipient is certified. You can ask us for more information about these safeguards.
10. Security and data breaches
We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, change or disclosure (APP 11; GDPR Art. 32). These steps include encrypted connections (TLS/SSL), access controls, restricted administrative access, server monitoring and regular security reviews. If a data breach is likely to cause you serious harm, we will notify you and the Office of the Australian Information Commissioner under the Notifiable Data Breaches scheme, and the relevant EU authority where the GDPR requires it.
11. How long we keep personal information
| Information | Retention period |
|---|---|
| Server log data | Up to 60 days, or longer if needed to investigate a specific security incident |
| Cookie preferences | 12 months, then we ask you again |
| Analytics data (Google Analytics) | The shortest period Google Analytics allows (currently 2 months) |
| Enquiries and correspondence | 12 months after your enquiry is resolved |
| Newsletter data | Until you unsubscribe; we then keep the consent record for up to 3 years as proof of consent |
| Information needed for legal claims or obligations | For the applicable legal limitation or retention period |
When we no longer need personal information, we destroy or de-identify it.
12. Access, correction and your other rights
You can ask to access the personal information we hold about you (APP 12) and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading (APP 13). Email info@extravirgine.online. We will respond within 30 days and there is no charge. We may need to confirm your identity first. If we refuse a request, we will explain why in writing and tell you how to complain.
Because we are established in the EU, you also have the following rights under the GDPR: erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), objection to processing based on legitimate interests and to direct marketing (Art. 21), and withdrawal of consent at any time (Art. 7(3)). We do not make decisions about you based solely on automated processing (Art. 22).
13. Complaints
If you have a concern about how we have handled your personal information, please email us first at info@extravirgine.online. We will acknowledge your complaint promptly and aim to resolve it within 30 days.
If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC):
Website: www.oaic.gov.au
Phone: 1300 363 992
You can also complain to our lead EU supervisory authority, the Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate), at www.aki.ee or info@aki.ee.
14. Age restriction
This website is only intended for people aged 18 and over. We do not knowingly collect personal information from anyone under 18. If you think a minor has given us personal information, please contact us and we will delete it.
15. Changes to this policy
We may update this policy from time to time. The current version will always be published on this page with its effective date. If we make significant changes, we will highlight them on the website and, where required, ask for your consent again.
16. Contact us
For privacy questions, access or correction requests, marketing opt-outs or complaints, contact:
Extravirgine
Juubelitammede tee 16
Saku alevik, Saku vald
Harju maakond, 75501
Estonia
Email: info@extravirgine.online