Privacy Policy

Welcome to Spinko. This Privacy Policy describes how Spinko, operated by [Company Name, if you have one, or "the entity operating Spinko"], collects, uses, processes, and protects your personal information when you use our website, mobile applications, and related services (collectively, "Services"). We are committed to protecting your privacy and handling your data in a transparent and secure manner. This policy explains your rights regarding your personal data and how we comply with applicable data protection laws, including the General Data Protection Regulation (GDPR) for users within the European Economic Area (EEA) and other relevant regulations globally. By accessing or using Spinko's Services, you agree to the terms of this Privacy Policy.

We collect various types of information to provide and improve our Services. This information can be categorised as follows:

• Information you provide directly: This includes data you submit during registration, such as your full name, date of birth, gender, email address, postal address, phone number, and password. When you make deposits or withdrawals, we collect payment information, including bank account details, credit/debit card numbers, and other financial transaction data. For identity verification purposes, you may be asked to provide copies of identification documents like passports, driving licenses, or utility bills.
• Information collected automatically: When you interact with Spinko's Services, we automatically collect certain technical and usage data. This includes your IP address, device type, operating system, browser type, referring URLs, pages viewed, time spent on pages, and clickstream data. We also record your gaming activity, such as bets placed, games played, winnings, and losses.
• Information from third parties: We may receive information about you from third-party service providers, such as identity verification services, fraud prevention agencies, and financial institutions. This data helps us verify your identity, prevent fraud, and comply with our legal and regulatory obligations.

Spinko uses the collected information for several essential purposes:

• To provide and manage our Services: This includes creating and maintaining your account, processing your transactions, enabling you to participate in games, and providing customer support.
• For security and fraud prevention: We use your data to verify your identity, detect and prevent fraudulent activities, money laundering, and other illegal or prohibited activities. This is crucial for maintaining the integrity of Spinko's platform.
• To comply with legal and regulatory obligations: As a licensed online casino, Spinko is subject to strict regulatory requirements. We use your data to comply with anti-money laundering (AML) laws, know your customer (KYC) regulations, responsible gambling policies, and other legal mandates.
• To improve and personalise your experience: We analyse usage data to understand how our Services are used, identify areas for improvement, and personalise your gaming experience, including offering tailored promotions and content.
• For marketing and promotional purposes: With your consent where required, we may send you marketing communications about Spinko's promotions, bonuses, and new games. You can opt out of these communications at any time.
• For research and analytics: We use aggregated and anonymised data for internal research, statistical analysis, and business planning.

Under applicable data protection laws, particularly the GDPR, Spinko processes your personal data based on one or more of the following legal grounds:

• Performance of a contract: Processing is necessary for the performance of the contract to which you are a party, specifically the Terms and Conditions of Spinko you accept when registering. This includes managing your account, processing transactions, and providing gaming services.
• Legal obligation: Processing is necessary for compliance with a legal obligation to which Spinko is subject. This covers our obligations under anti-money laundering laws, responsible gambling regulations, and other regulatory requirements imposed by our licensing authority.
• Legitimate interests: Processing is necessary for the purposes of the legitimate interests pursued by Spinko or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms. Our legitimate interests include fraud prevention, enhancing security, improving our Services, and marketing our products, provided your rights are protected.
• Consent: In specific situations, we may rely on your explicit consent to process certain types of personal data, particularly for marketing communications or specific data analytics. Where consent is the legal basis, you have the right to withdraw your consent at any time.

Spinko may share your personal information with third parties under specific circumstances:

• Service Providers: We engage trusted third-party service providers to perform functions on our behalf, such as payment processors, identity verification services, IT and hosting providers, customer support platforms, and marketing agencies. These providers are contractually bound to protect your data and only use it for the purposes for which it was disclosed.
• Regulatory Bodies and Law Enforcement: We will disclose your personal data when legally required to do so by our licensing authority, government agencies, or law enforcement bodies in response to a valid request, court order, or subpoena. This includes reporting suspicious transactions or activities.
• Fraud Prevention and Responsible Gambling Organisations: To protect our users and comply with industry standards, we may share data with organisations dedicated to fraud prevention and promoting responsible gambling.
• Business Transfers: In the event of a merger, acquisition, reorganisation, or sale of all or a portion of our assets, your personal data may be transferred as part of that transaction. We will notify you of any such change in ownership or control.
• Affiliated Companies: We may share data with companies within our corporate group for internal administrative purposes, service provision, and compliance.

We do not sell your personal data to third parties.

Spinko implements robust technical and organisational measures to protect your personal data from unauthorised access, alteration, disclosure, or destruction. We use industry-standard security technologies, including SSL encryption for data transmission, firewalls, and secure server environments. Access to your personal data is restricted to authorised employees and service providers who need the information to perform their duties. We regularly review our security procedures and update them as necessary to maintain a high level of protection. While we strive to protect your personal information, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

Depending on your jurisdiction, you may have the following rights regarding your personal data held by Spinko:

• 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.
• Right to Erasure (Right to be Forgotten): You may request the deletion of your personal data under certain circumstances, 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 situations, 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 to transmit that data to another controller.
• Right to Object: You have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where we rely on your consent for processing, you have the right to withdraw that consent at any time.
• 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 below. We will respond to your request in accordance with applicable data protection laws.

Spinko uses cookies and similar tracking technologies to enhance your experience, analyse website usage, and for marketing purposes. Cookies are small text files stored on your device when you visit our website. They help us remember your preferences, keep you logged in, and understand how you interact with our Services.

• Essential Cookies: These are necessary for the website to function correctly, enabling core functionalities like security, network management, and accessibility.
• Analytical/Performance Cookies: These cookies help us understand how visitors interact with our website by collecting information about pages visited, time spent on the site, and any error messages. This helps us improve website performance.
• Functionality Cookies: These are used to remember choices you make, such as your username, language, or region, to provide enhanced, more personal features.
• Advertising/Targeting Cookies: These cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and help measure the effectiveness of advertising campaigns.

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, disabling cookies may prevent you from taking full advantage of the website's features.

Spinko retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Our retention periods are determined by various factors, including the type of data, the purpose of processing, and legal or regulatory obligations. For instance, we are typically required to retain certain transactional and account data for a minimum of five years after the termination of your account, in compliance with anti-money laundering regulations. After the applicable retention period, your personal data will be securely deleted or anonymised.

Spinko may transfer your personal data to countries outside of your country of residence, including countries outside the European Economic Area (EEA), where data protection laws may not be as comprehensive as those in your home jurisdiction. When we transfer your data internationally, we implement appropriate safeguards to ensure your personal data remains protected. These safeguards may include reliance on standard contractual clauses approved by the European Commission, ensuring the recipient country has been deemed to provide an adequate level of protection, or obtaining your explicit consent. We ensure that any such transfers comply with applicable data protection laws.

Spinko's Services are strictly not intended for individuals under the age of 18 (or the legal age of majority in your jurisdiction, if 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. If you believe we might have any information from or about a child, please contact us immediately.

Spinko may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technological advancements. We will notify you of any significant changes by posting the updated policy on our website and, where appropriate, by email or other direct communication. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. 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 our Data Protection Officer:

Email: [email protected]

We are committed to addressing your inquiries promptly and transparently.