Privacy Policy

Welcome to Spinko. We are committed to protecting your privacy and handling your personal data with transparency and care. This Privacy Policy explains how Spinko collects, uses, stores, and discloses your personal information when you use our website, services, and applications (collectively, "Services"). It also describes your rights regarding your personal data. By using Spinko's Services, you agree to the terms of this Privacy Policy. We encourage you to read this policy carefully to understand our practices.

We collect various types of information to provide and improve our Services. This includes:

• Identity Data: Your full name, date of birth, gender, and nationality. We require this to verify your age and identity, a legal obligation for online gambling operators.
• Contact Data: Your residential address, email address, and telephone number. We use this to communicate with you about your account and our Services.
• Financial Data: Bank account details, payment card details, and other payment information. This is necessary for processing deposits and withdrawals. We do not store full payment card numbers, instead, we use secure, tokenized systems provided by our payment processors.
• Transaction Data: Details about your deposits, withdrawals, wagers, and other activities on our platform. This helps us manage your account and comply with regulatory requirements.
• Technical Data: Your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Services. This information assists us in maintaining security and optimizing user experience.
• Profile Data: Your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses. This data helps us personalize your experience.
• Usage Data: Information about how you use our website, products, and services. This includes pages viewed, time spent on pages, and navigation paths. We use this to understand user behavior and improve our offerings.
• Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties, and your communication preferences.
• Verification Data: Documents you provide to prove your identity and address, such as copies of passports, driver's licenses, utility bills, or bank statements. This is a crucial part of our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations.

Spinko uses your personal information for several purposes, primarily to operate our Services, comply with legal obligations, and enhance your user experience:

• To Provide and Manage Services: This includes setting up and managing your account, processing your transactions (deposits and withdrawals), and delivering the gaming services you request.
• To Verify Your Identity: We use your data to confirm your age and identity as required by law, preventing underage gambling and fraud.
• To Comply with Legal and Regulatory Obligations: This involves meeting requirements related to anti-money laundering (AML), responsible gambling, and reporting to our licensing authority.
• To Enhance and Personalize Your Experience: We analyze your usage data to understand your preferences, allowing us to offer tailored games, promotions, and content.
• For Security and Fraud Prevention: We use technical and transaction data to detect and prevent fraudulent activities, unauthorized access, and other security incidents.
• For Communication: We use your contact details to send you important updates about your account, service notifications, and, with your consent, marketing communications about our products and promotions.
• For Customer Support: To respond to your inquiries, resolve issues, and provide assistance when you contact us.
• For Internal Business Operations: Including data analysis, testing, research, statistical purposes, and to improve our website, products, and services.

Under data protection laws, particularly the GDPR, we must have a legal basis to process your personal data. At Spinko, we rely on the following bases:

• Contractual Necessity: Processing is necessary for the performance of a contract with you, or to take steps at your request before entering into such a contract. This applies to creating and managing your account, processing transactions, and providing access to our games.
• Legal Obligation: Processing is necessary for compliance with a legal or regulatory obligation to which we are subject. This includes age verification, identity checks, anti-money laundering (AML) requirements, responsible gambling measures, and reporting to authorities.
• Legitimate Interests: Processing is necessary for the purposes of our legitimate interests or those of a third party, provided your fundamental rights and freedoms do not override those interests. This includes improving our Services, fraud prevention, network and information security, direct marketing (where consent is not required), and analytics to understand user behavior.
• Consent: In specific situations, we may ask for your explicit consent to process your personal data, for example, for certain marketing communications. You have the right to withdraw your consent at any time.

Spinko may share your personal information with third parties under specific circumstances, always ensuring appropriate safeguards are in place:

• Service Providers: We work with trusted third-party service providers who perform functions on our behalf, such as payment processors, IT support, hosting providers, customer service platforms, and marketing agencies. These providers are contractually bound to protect your data and only use it for the purposes we specify.
• Regulatory and Law Enforcement Authorities: We will disclose your data when legally required to do so, for example, to comply with a court order, subpoena, or government request, or to meet our obligations to our licensing authority and other regulatory bodies. This includes reporting suspicious transactions in line with AML regulations.
• Fraud Prevention and Identity Verification Agencies: To prevent fraud, money laundering, and underage gambling, we may share your information with specialized agencies for identity verification and risk assessment.
• Group Companies: Your data may be shared within our corporate group for internal administrative purposes, such as shared IT systems or customer support.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred to the acquiring entity. We will notify you of any such change in ownership or control of your personal data.
• Analytics Providers: We may share anonymized or aggregated data with analytics providers to help us understand user behavior and improve our Services. This data cannot be used to identify you personally.

We do not sell your personal data to third parties.

Spinko takes the security of your personal data seriously. We implement a range of technical and organizational measures designed to protect your information from unauthorized access, accidental loss, destruction, or alteration. These measures include:

• Encryption: We use Secure Socket Layer (SSL) encryption technology to protect your data during transmission over the internet, particularly for sensitive information like financial details.
• Access Controls: Access to your personal data is restricted to authorized Spinko employees and service providers who require it to perform their job functions. These individuals are subject to strict confidentiality obligations.
• Firewalls and Intrusion Detection Systems: We employ firewalls and other network security measures to protect our systems from external threats.
• Regular Security Audits: Our systems undergo regular security assessments and penetration testing to identify and address vulnerabilities.
• Data Minimization: We only collect and retain personal data that is necessary for the purposes outlined in this policy.

While we strive to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security. We also encourage you to play a role in protecting your data by choosing a strong, unique password and keeping your login credentials confidential.

As a data subject, you have several rights regarding your personal data. Spinko is committed to facilitating the exercise of these rights:

• Right to Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You can request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure ("Right to be Forgotten"): You can request the deletion of your personal data, under certain conditions, such as when the data is no longer necessary for the purposes for which it was collected.
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances, for example, if you contest the accuracy of the data.
• Right to Data Portability: You can request to receive your personal data in a structured, commonly used, and machine-readable format, and have the right to transmit that data to another controller, where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data, particularly where we are relying on legitimate interests as our legal basis, or for direct marketing purposes.
• Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been violated.

To exercise any of these rights, please contact us using the details provided in the "Contact Us" section. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Spinko uses cookies and similar tracking technologies to enhance your experience, analyze website usage, and for marketing purposes. Cookies are small text files placed on your device when you visit our website.

• Strictly Necessary Cookies: These cookies are essential for the operation of our website and enable core functionalities such as security, network management, and accessibility. Without these, our Services cannot be provided.
• Analytical/Performance Cookies: These allow us to recognize and count the number of visitors and see how visitors move around our website when they are using it. This helps us improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality Cookies: These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
• Targeting/Advertising Cookies: These cookies record your visit to our website, the pages you have visited, and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You have the option to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the website. For more detailed information on how we use cookies, please refer to our separate Cookie Policy.

Spinko retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. The specific retention periods depend on the type of data and the purpose of processing.

• Account Data: We generally retain your account information for the duration of your active account with Spinko and for a period thereafter as required by our licensing authority and anti-money laundering regulations, typically five years after account closure.
• Transaction Data: Financial transaction records are retained for a minimum of five years, and sometimes longer, to comply with tax and financial regulations.
• Marketing Consent: If you have provided consent for marketing communications, we will retain your contact details for marketing purposes until you withdraw your consent or object to such processing.
• Security and Fraud Prevention Data: Data collected for security and fraud prevention may be retained for longer periods if necessary for ongoing investigations or legal proceedings.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Spinko operates globally, and some of our service providers or group companies may be located outside of your country of residence, including outside the European Economic Area (EEA). This means your personal data may be transferred to and stored in countries that may not provide the same level of data protection as your home country.

When we transfer your personal data internationally, we take appropriate safeguards to ensure your data is protected in accordance with this Privacy Policy and applicable data protection laws. These safeguards may include:

• Transferring data to countries deemed by the European Commission to provide an adequate level of protection for personal data.
• Using standard contractual clauses (SCCs) approved by the European Commission, which provide specific data protection obligations for the recipient of the data.
• Implementing binding corporate rules (BCRs) for transfers within our corporate group, where applicable.
• Obtaining your explicit consent for the transfer after informing you of the possible risks.

By using Spinko's Services, you understand and agree to the international transfer of your personal data as described in this section.

Spinko's Services are strictly not intended for individuals under the legal gambling age (18 years or the age of majority in your jurisdiction, whichever is higher). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal data from a child, we will take immediate steps to delete that information from our records.

We implement robust age verification procedures during the account registration process to prevent underage access to our platform. If you believe that a child has provided us with personal information, please contact us immediately so we can take appropriate action.

Spinko may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technological advancements. When we make significant changes, we will notify you by posting the updated policy on our website and, where appropriate, by sending you an email notification or placing a prominent notice on our platform.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. The "Last Updated" date at the top of this policy indicates when it was last revised. Your continued use of Spinko's Services after any changes to this Privacy Policy constitutes your acceptance of the revised terms.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please do not hesitate to contact us. Our dedicated support team is available to assist you.

You can reach us through the following channels:

• Email: [email protected]
• Live Chat: Available on our website during operational hours.
• Postal Address: [Please refer to the "Terms and Conditions" or "About Us" section on our website for our registered office address, as this policy is general.]

We aim to respond to all legitimate requests within a reasonable timeframe, typically within one month. We may require you to verify your identity before processing your request.