Privacy Policy

Welcome to Spinko. We are committed to protecting your privacy and handling your personal information with transparency and care. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our website, services, and applications (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 data.

This policy applies to all users of Spinko, regardless of how you access our Services. We operate under the regulations of our licensing authority, ensuring that our data processing activities comply with applicable data protection laws, including the General Data Protection Regulation (GDPR) where it applies to our operations.

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

• Personal Identifiable Information (PII): This includes your full name, date of birth, gender, home address, email address, telephone number, and national identification numbers (e.g., passport or driving license details) for identity verification purposes. We also collect payment information, such as credit/debit card details or other financial account information, necessary for deposits and withdrawals.
• Account Information: Your username, password (encrypted), and security questions/answers.
• Transactional Data: Details of your bets, deposits, withdrawals, and other activities on Spinko. This includes game play history and transaction IDs.
• Technical Data: Your IP address, browser type and version, operating system, device type, unique device identifiers, and information about how you interact with our Services.
• Communication Data: Records of your correspondence with us, including emails, live chat transcripts, and phone calls.
• Usage Data: Information about your preferences, interests, and how you use our Services, such as pages visited, time spent on pages, and features accessed.
• Publicly Available Information: In some cases, we may collect information about you from public sources, such as public registers or social media, for identity verification or fraud prevention.

We use the information we collect for several essential purposes:

• To Provide and Manage Services: This includes creating and managing your Spinko account, processing your transactions, and allowing you to participate in games and activities.
• Identity Verification and Security: We use your PII to verify your identity, prevent fraud, money laundering, and other illegal activities, and ensure compliance with our regulatory obligations. This is a crucial aspect of responsible gaming and security at Spinko.
• Customer Support: To respond to your inquiries, resolve issues, and provide assistance when needed.
• Personalization: To tailor our Services, content, and offers to your preferences and interests, enhancing your experience on Spinko.
• Marketing and Promotions: To send you information about promotions, bonuses, new games, and other offers that may be of interest to you, where you have consented to receive such communications. You can opt out of marketing communications at any time.
• Service Improvement: To analyze usage patterns, troubleshoot technical issues, and continuously improve the functionality, performance, and security of our Services.
• Legal and Regulatory Compliance: To comply with our legal and regulatory obligations, including age verification, responsible gaming checks, and reporting requirements to our licensing authority.
• Risk Management: To monitor and detect suspicious activities and manage financial and operational risks.

We process your personal information based on the following legal grounds:

• Performance of a Contract: Processing is necessary for the performance of the contract between you and Spinko, such as providing gaming services and managing your account.
• Legal Obligations: Processing is necessary for compliance with a legal obligation to which we are subject, including anti-money laundering (AML) regulations, age verification, and responsible gaming requirements imposed by our licensing authority.
• Legitimate Interests: Processing is necessary for our legitimate interests or those of a third party, provided your fundamental rights do not override these interests. This includes improving our Services, preventing fraud, ensuring network and information security, and direct marketing where permitted by law.
• Consent: In specific situations, we may ask for your explicit consent to process your data for certain purposes, such as sending you marketing communications. You have the right to withdraw your consent at any time.

We do not sell your personal information. We may share your information with third parties only in specific circumstances and in accordance with this Privacy Policy:

• Service Providers: We engage trusted third-party service providers to perform functions on our behalf, such as payment processors, IT infrastructure providers, customer support platforms, and identity verification services. These providers are contractually bound to protect your data and use it only for the purposes for which it was shared.
• Regulatory and Law Enforcement Authorities: We may disclose your information if required by law, regulation, or court order, or if we believe such disclosure is necessary to protect our rights, property, or safety, or the rights, property, or safety of others. This includes sharing information with our licensing authority and other relevant bodies for fraud prevention and regulatory compliance.
• Affiliates and Group Companies: Your data may be shared with companies within our corporate group for operational purposes, internal reporting, and to offer you integrated services.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal information may be transferred to the acquiring entity. We will notify you of any such change in ownership or control of your personal information.
• Anonymized Data: We may share aggregated or anonymized data that does not identify you personally for research, analytical, or marketing purposes.

We are committed to protecting your personal information from unauthorized access, alteration, disclosure, or destruction. We implement a range of technical and organizational security measures, including:

• Encryption: We use Secure Socket Layer (SSL) encryption technology to protect your data during transmission.
• Access Controls: Access to your personal data is restricted to authorized personnel who require it for their job functions and are bound by confidentiality obligations.
• 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.
• Data Minimization: We only collect and retain personal data that is necessary for the purposes for which it is processed.

While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee absolute security.

Depending on your jurisdiction, and particularly under GDPR, you have several rights regarding your personal information:

• Right to Access: You have the right to request a copy of the personal information we hold about you.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.
• Right to Erasure (Right to be Forgotten): You have the right to request the deletion of your personal information under certain circumstances, for example, if the data is no longer necessary for the purposes for which it was collected.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information under certain conditions, such as when you contest the accuracy of the data.
• Right to Object to Processing: You have the right to object to the processing of your personal information where we are relying on legitimate interests as our legal basis.
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
• 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.
• 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 may need to verify your identity before fulfilling your request.

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

• Essential Cookies: These are necessary for the website to function correctly, enabling basic features like account login, secure transactions, and remembering your preferences.
• 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 error messages. This helps us improve the performance of Spinko.
• Functionality Cookies: These are used to remember choices you make (such as your username, language, or region) and provide enhanced, more personal features.
• Targeting/Advertising 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 manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of our Services.

We retain your personal information 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. Our retention periods are determined by a number of factors, including:

• The duration of your active account with Spinko.
• Legal and regulatory obligations, such as anti-money laundering laws, which require us to retain certain transaction data for a specified period (typically 5-7 years after account closure).
• The need to resolve disputes, enforce our agreements, or protect our legal rights.

When your personal information is no longer required, we will securely delete or anonymize it.

Your personal information may be transferred to, and stored at, a destination outside of your country of residence, including countries outside the European Economic Area (EEA), where data protection laws may differ. When we transfer your data internationally, we take appropriate safeguards to ensure your data receives an adequate level of protection. This may include using standard contractual clauses approved by the European Commission or relying on the recipient's certification under relevant frameworks.

Spinko's Services are strictly not intended for individuals under the age of 18 (or the legal 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 information from a child, we will take steps to delete that information promptly. 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 regulatory obligations. 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. We encourage you to review this 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 policy.

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

Email: [email protected]

Postal Address:
Spinko Data Protection Officer
[Our Registered Office Address, as provided to our licensing authority]

We aim to respond to all legitimate requests within one month.