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 we collect, use, disclose, and protect your information when you use our online casino services, including our website, mobile applications, and any other related services (collectively, "Services"). By accessing or 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 regarding your personal data.

Spinko operates under a license issued by our licensing authority. We adhere to all applicable data protection laws and regulations, including the General Data Protection Regulation (GDPR), where relevant. This policy outlines your rights concerning your personal data and how you can exercise them.

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

• Personal Identifiable Information (PII): This includes data you provide directly when you register an account, verify your identity, deposit funds, or contact customer support. Examples include your full name, date of birth, residential address, email address, phone number, and payment details (such as credit card numbers or e-wallet information). We also collect identification documents, like passports or driver's licenses, for identity verification and anti-money laundering (AML) purposes.
• Transactional Data: We record details of your betting activity, deposits, withdrawals, and other transactions made through your Spinko account. This includes game play history, stakes, winnings, and losses.
• Technical Data: When you access our Services, we automatically collect information about your device and how you interact with our platform. This includes your IP address, browser type and version, operating system, device identifiers, time zone setting, browser plug-in types and versions, and referring URLs.
• Usage Data: We collect information about your activities on Spinko, such as pages viewed, features used, session duration, and clickstream data. This helps us understand how our Services are used and allows us to enhance your experience.
• Communication Data: If you communicate with us via email, live chat, or other channels, we may record these communications. This helps us resolve queries, train our staff, and improve our customer service.

We use the information we collect for several essential purposes, all aimed at providing a secure, enjoyable, and compliant gaming experience at Spinko:

• To Provide and Manage Services: This includes creating and maintaining your account, processing your bets and transactions, and providing access to games and features.
• For Identity Verification and Security: We use your PII to verify your identity, prevent fraud, detect and prevent money laundering, and ensure compliance with our regulatory obligations. This is a crucial aspect of responsible gaming and security.
• To Process Payments: We use your payment details to facilitate deposits and withdrawals securely.
• For Customer Support: Your information helps us respond to your inquiries, resolve technical issues, and provide effective assistance.
• To Personalise Your Experience: We may use usage data to tailor game recommendations, promotions, and content to your preferences.
• For Marketing and Promotions: With your consent, or where otherwise permitted by law, we may send you marketing communications about Spinko's products, services, and promotions. You can opt out of these communications at any time.
• For Analytics and Improvement: We analyse usage and technical data to understand how our Services are used, identify areas for improvement, and develop new features.
• To Comply with Legal and Regulatory Obligations: We use your data to meet our legal duties, including reporting to regulatory authorities, enforcing our terms and conditions, and preventing illegal activities.

We process your personal data only when we have a valid legal basis to do so. These bases include:

• Contractual Necessity: Processing is necessary for the performance of a contract with you, such as providing our gaming services and managing your account.
• Legal Obligation: Processing is necessary for compliance with a legal obligation to which Spinko is subject, including anti-money laundering laws, age verification, and responsible gaming regulations.
• Legitimate Interests: Processing is necessary for our legitimate interests or those of a third party, provided these interests do not override your fundamental rights and freedoms. Our legitimate interests include improving our services, preventing fraud, ensuring network and information security, and marketing our services.
• Consent: We may rely on your explicit consent for certain processing activities, particularly for sending direct marketing communications or for specific data analyses. Where we rely on consent, you have the right to withdraw it at any time.

We do not sell your personal data to third parties. However, we may share your information with certain trusted entities under specific circumstances:

• Service Providers: We engage third-party service providers to perform functions on our behalf, such as payment processors, IT support, identity verification services, and marketing agencies. These providers are contractually obligated to protect your data and use it only for the purposes we specify.
• Regulatory and Law Enforcement Authorities: We may disclose your data when required by law, court order, or governmental regulation, or when we believe such disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request. This includes sharing information with our licensing authority.
• Affiliates and Business Partners: We may share data with our corporate affiliates or trusted business partners where necessary to provide our services or for legitimate business purposes, always under strict confidentiality agreements.
• Auditors and Professional Advisors: We may share your data with auditors, lawyers, and other professional advisors as necessary for compliance, legal, or accounting purposes.
• 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.

Spinko is committed to protecting your personal data from unauthorised access, alteration, disclosure, or destruction. We implement a variety of technical and organisational security measures, including:

• Encryption: We use Secure Socket Layer (SSL) encryption technology to protect data transmission over the internet.
• Access Controls: Access to your personal data is restricted to authorised personnel who require it to perform their job functions.
• Firewalls: Our systems are protected by firewalls to prevent unauthorised access.
• Regular Audits: We conduct regular security audits and assessments to identify and address potential vulnerabilities.
• Employee Training: Our employees receive regular training on data protection and privacy best practices.

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

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

• 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 circumstances, for example, if 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, such as when 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, particularly when processing is 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. This will not affect the lawfulness of processing based on consent before its withdrawal.
• Right to Complain: 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 may require you to verify your identity before fulfilling your request.

Spinko uses cookies and similar tracking technologies to enhance your experience, analyse website usage, and for marketing purposes. Cookies are small text files placed on your device by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

We use:

• Essential Cookies: These are necessary for the operation of our website, enabling core functionalities like security, network management, and accessibility. Without these cookies, our services cannot be provided.
• Analytical/Performance Cookies: These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to 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 recognise you when you return to our website. This enables us to personalise 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 can manage your cookie preferences through your browser settings. Most browsers allow you to refuse all or some cookies, or to alert you when websites set or access cookies. Please note that disabling essential cookies may affect the functionality and your ability to use Spinko's Services.

We retain 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:

• Regulatory Obligations: Gaming regulations and anti-money laundering laws require us to retain certain data for a specified period after your account closure.
• Contractual Obligations: We retain data as long as you have an active account with Spinko to provide our services.
• Legal Claims: We may retain data for longer periods if it is necessary for potential legal claims or disputes.
• Business Needs: We retain data for legitimate business purposes, such as improving our services and maintaining accurate business records.

Once the retention period expires, your personal data will be securely deleted or anonymised.

Spinko operates globally, and your personal data may be transferred to, and stored at, a destination outside of your country of residence, including countries that may not offer the same level of data protection as your home jurisdiction. When we transfer your 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 to provide an adequate level of protection by relevant authorities.
• Implementing standard contractual clauses approved by regulatory bodies.
• Relying on your explicit consent for specific transfers.

By using Spinko's Services, you acknowledge and agree to such international transfers of your personal data.

Spinko's Services are strictly not intended for individuals under the legal gambling age in their respective jurisdiction, which is typically 18 years or older. We do not knowingly collect personal data 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.

We 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 other means such such as email. 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 indicates your acceptance of the updated Privacy Policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please do not hesitate to contact us:

• By Email: [email protected]
• Through Live Chat: Available on our website during operational hours.
• By Post: Our registered office address, which can be found in our Terms and Conditions.

We will respond to your inquiries as quickly as possible and in accordance with applicable data protection laws.