Privacy Policy

Effective Date: October 26, 2023

Welcome to Spinsy. We protect your privacy and the security of your personal data. This Privacy Policy outlines how we collect, use, process, and disclose your information when you access or use our services. We aim to provide you with a clear understanding of our data practices. By using Spinsy's services, you agree to the terms of this Privacy Policy. Please read it carefully.

This policy applies to all visitors, users, and others who access the service. We operate in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR), where relevant. Your trust is important to us, and we maintain high standards of data protection.

To provide services and a secure gaming environment, Spinsy collects various types of information. This includes:

• Personal Identifiable Information (PII): This includes your name, date of birth, email address, postal address, phone number, and identification documents (e.g., passport, driver's license) required for identity verification and compliance with regulatory obligations.
• Financial Information: Details related to your payment methods, such as bank account numbers, credit/debit card details, and e-wallet information. We do not store full credit card numbers, only a tokenized version for processing transactions.
• Transactional Data: Information about your betting activity, deposits, withdrawals, and other transactions made on Spinsy.
• Technical Data: This encompasses your IP address, browser type and version, operating system, device type, login data, time zone setting, and other technology on the devices you use to access our website.
• Usage Data: Information about how you use our website, products, and services, including pages viewed, time spent on pages, and navigation paths.
• Communication Data: Records of your interactions with our customer support, including emails, chat logs, and phone calls.
• Marketing and Communications Preferences: Your preferences in receiving marketing from us and our third parties, and your communication preferences.

Spinsy uses the collected information for various purposes, primarily to provide, maintain, and improve our services. We use your data to:

• Process your registrations and manage your account: This includes verifying your identity, setting up your account, and managing your login credentials.
• Facilitate transactions: Processing your deposits and withdrawals, and securing financial operations.
• Provide customer support: Responding to your inquiries, resolving issues, and providing assistance.
• Ensure responsible gaming: Monitoring gaming patterns to identify and prevent problem gambling, in line with our commitment to player welfare.
• Comply with legal and regulatory obligations: Fulfilling requirements from our licensing authority, preventing fraud, money laundering, and other illegal activities.
• Improve our services: Analyzing usage data to enhance user experience, optimize website functionality, and develop new features.
• Personalize your experience: Tailoring content, promotions, and offers based on your preferences and gaming history.
• Send marketing communications: With your consent, we may send you promotional materials about our products, services, and special offers. You can opt out at any time.
• Maintain security: Protecting our website and systems from unauthorized access, cyber threats, and other security risks.

Spinsy processes your personal data based on several legal grounds, as required by data protection laws:

• Performance of a contract: Processing is necessary for the performance of the contract between you and Spinsy, specifically to provide you with our gaming services.
• Legal obligations: Processing is necessary for compliance with a legal obligation to which we are subject, such as anti-money laundering (AML) regulations, fraud prevention, and responsible gambling requirements.
• Legitimate interests: Processing is necessary for our legitimate interests, or those of a third party, provided that your fundamental rights and freedoms do not override those interests. This includes improving our services, preventing fraud, securing the network and information, and direct marketing where permitted by law.
• Consent: In certain situations, we may rely on your explicit consent to process your personal data, particularly for marketing communications. You have the right to withdraw your consent at any time.

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

• Service Providers: We engage trusted third-party service providers to perform functions on our behalf, such as payment processors, identity verification services, IT and software providers, and customer support platforms. These providers are contractually bound to protect your data and only use it for the purposes specified by Spinsy.
• Regulatory and Law Enforcement Authorities: We may disclose your information to government bodies, regulators, or law enforcement agencies if required by law or in good faith belief that such action is necessary to comply with legal obligations, protect our rights or property, or ensure the safety of our users.
• Group Companies: Your data may be shared with other entities within our corporate group for operational purposes, internal reporting, and service improvement.
• Fraud Prevention Agencies: To prevent fraud and money laundering, we may share your data with specialized agencies.
• 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.
• With Your Consent: We may share your information with third parties when we have your explicit consent to do so.

We do not sell your personal data to third parties for their marketing purposes.

Spinsy protects your personal data from unauthorized access, alteration, disclosure, or destruction. We implement robust technical and organizational security measures, including:

• Encryption: All sensitive data, including financial transactions and personal information, is encrypted using industry-standard SSL (Secure Socket Layer) technology.
• Access Controls: Access to your personal data is restricted to authorized personnel who have a legitimate business need to access it.
• Firewalls: Our systems are protected by firewalls to prevent unauthorized access.
• Regular Audits: We conduct regular security audits and vulnerability assessments to identify and address potential weaknesses.
• Employee Training: Our staff receives regular training on data protection best practices and security protocols.

While we use commercially acceptable means to protect your personal data, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

Under applicable data protection laws, you have several rights regarding your personal data. Spinsy respects these rights and provides mechanisms for you to exercise them:

• Right to Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure ('Right to be Forgotten'): You have the right to request the deletion of your personal data under certain circumstances (e.g., 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 under certain conditions (e.g., if you contest the accuracy of the data).
• Right to Data Portability: You have the right 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 in cases of direct marketing or processing based on legitimate interests.
• Right to Withdraw Consent: Where we rely on your consent to process your 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 your local data protection supervisory authority if you believe your 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 within the legally required timeframe.

Spinsy 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 by websites that you visit.

• Essential Cookies: These are necessary for the website to function correctly, enabling core functionalities like secure login and transaction processing.
• Analytical/Performance Cookies: These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. This helps us improve website performance.
• Functionality Cookies: These are used to remember your preferences (e.g., language, region) and provide enhanced, more personal features.
• Marketing/Targeting Cookies: These cookies record your visit to our website, the pages you have visited, and the links you have followed. We use this information to make our website and the advertising displayed on it more relevant to your interests.

You can 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.

Spinsy 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 retention period for different types of data varies based on:

• Legal and Regulatory Obligations: We are required to retain certain data for specific periods to comply with anti-money laundering (AML) regulations, tax laws, and other regulatory requirements imposed by our licensing authority.
• Contractual Obligations: Data related to your account and transactions is retained for the duration of our contractual relationship and for a period thereafter to address any potential disputes or issues.
• Business Needs: We may retain data for legitimate business interests, such as fraud prevention, security, and service improvement, provided that such retention is not overridden by your data protection rights.
• Consent: If we process data based on your consent, we will retain it until you withdraw your consent, or until it is no longer necessary for the purpose for which consent was given.

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

Spinsy operates globally, and as such, your personal data may be transferred to, and stored at, a destination outside of your country of residence, including countries outside the European Economic Area (EEA). These countries may not have the same data protection laws as your jurisdiction.

When we transfer your personal data internationally, we take appropriate safeguards to ensure that your data is treated securely and 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 data protection by the European Commission.
• Implementing Standard Contractual Clauses (SCCs) approved by the European Commission, which provide specific data protection obligations for the recipient.
• Obtaining your explicit consent for the transfer.

By using Spinsy's services, you acknowledge and agree to such transfers.

Spinsy's services are not intended for individuals under the age of 18 (or the legal age for gambling in your jurisdiction, whichever is higher). 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 are a parent or guardian and believe your child has provided us with personal data, please contact us immediately using the details in the "Contact Us" section.

Spinsy reserves the right to update or modify this Privacy Policy at any time. Any changes will be posted on this page with an updated "Effective Date". We encourage you to review this policy periodically to stay informed about how we are protecting your information. Significant changes will be communicated to you through your registered email address or prominent notices on our website.

Your continued use of Spinsy'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 practices, please contact our Data Protection Officer:

• By Email: [email protected]
• Through our Website: Visit the "Contact Us" section on Spinsy.com for our online inquiry form.

We address your inquiries promptly and transparently.