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 related services (collectively, "Services"). By accessing or using Spinko, 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. We process your personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR) where it applies to our processing activities. We are dedicated to maintaining the confidentiality and security of your personal information.

We collect various types of information to provide and improve our Services. This includes information you provide directly to us, information collected automatically, and information obtained from third parties.

• Information You Provide Directly:
  • Registration and Account Information: When you create an account with Spinko, we collect your name, date of birth, gender, email address, postal address, telephone number, and chosen username and password.
  • Financial Information: For deposits and withdrawals, we collect payment card details (card number, expiry date, CVV, cardholder name) or other payment account details. We do not store full payment card numbers on our servers.
  • Verification Documents: To comply with regulatory requirements (e.g., Know Your Customer, Anti-Money Laundering), we may request copies of identification documents such as passports, driver's licenses, utility bills, or bank statements.
  • Communications: Records of your communications with us, including customer support inquiries, chat transcripts, emails, and any feedback you provide.
  • Participation in Promotions/Surveys: Information you provide when participating in contests, promotions, surveys, or other interactive features.
• Information Collected Automatically:
  • Device and Usage Information: We collect information about your device and how you interact with our Services. This includes your IP address, browser type, operating system, device identifiers, referring URLs, pages viewed, time spent on pages, and clickstream data.
  • Gaming Activity: Details of your gaming activity, including games played, bets placed, winnings, losses, and session duration.
  • Location Information: We may collect general location information derived from your IP address to comply with jurisdictional restrictions and for fraud prevention.
• Information from Third Parties:
  • Identity Verification and Fraud Prevention: We may receive information from third-party identity verification services, credit reference agencies, and fraud prevention agencies to verify your identity and prevent fraudulent activities.
  • Payment Processors: We receive transaction details from payment service providers to confirm deposits and withdrawals.
  • Publicly Available Information: In some cases, we may collect information from publicly available sources to comply with regulatory obligations or for enhanced due diligence.

We use the information we collect for various purposes, primarily to provide, maintain, and improve our Services, and to comply with our legal and regulatory obligations. Specifically, we use your data to:

• Provide and Manage Your Account: To set up and manage your Spinko account, process transactions, and provide customer support.
• Process Payments: To facilitate deposits and withdrawals, verify payment details, and prevent fraudulent transactions.
• Comply with Legal and Regulatory Obligations: To verify your identity, age, and location, perform Know Your Customer (KYC) and Anti-Money Laundering (AML) checks, and report to regulatory authorities as required.
• Ensure Responsible Gaming: To monitor gaming activity and implement responsible gaming measures, including self-exclusion and limits.
• Personalize Your Experience: To tailor content, offers, and promotions based on your gaming preferences and history.
• Communicate with You: To send you important updates, service announcements, promotional offers (where you have consented), and respond to your inquiries.
• Improve Our Services: To analyze usage patterns, troubleshoot technical issues, and enhance the functionality and user experience of Spinko.
• Detect and Prevent Fraud and Security Breaches: To protect our Services and users from fraudulent activities, unauthorized access, and other security threats.
• Conduct Research and Analytics: To understand market trends, conduct internal research, and develop new features and services.

Our legal basis for collecting and using your personal data depends on the specific context in which we collect it and the purposes for which it is used. We primarily rely on the following legal bases:

• Performance of a Contract: We process your data when it is necessary for the performance of a contract to which you are a party, such as the Terms and Conditions you agree to when creating an account and using our Services. This includes managing your account, processing transactions, and providing customer support.
• Legal Obligation: We process your data when it is necessary to comply with a legal or regulatory obligation. This includes age verification, identity checks (KYC/AML), responsible gaming measures, and reporting to regulatory bodies.
• Legitimate Interests: We may process your data where it 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 preventing fraud, enhancing security, improving our Services, personalizing your experience, and marketing (where consent is not required).
• Consent: In certain situations, we may rely on your explicit consent to process your personal data, particularly for sending direct marketing communications or for specific types of data processing not covered by the above bases. You have the right to withdraw your consent at any time.

We do not sell your personal data to third parties. We may share your information with trusted third parties under specific circumstances, always ensuring appropriate safeguards are in place.

• Service Providers: We engage third-party service providers to perform functions on our behalf, such as payment processing, identity verification, IT infrastructure, customer support, data analysis, and marketing services. These providers are contractually obligated to protect your data and only use it for the purposes we specify.
• Regulatory and Law Enforcement Authorities: We may disclose your information to government, regulatory, or law enforcement authorities if required by law, court order, or to cooperate with investigations into illegal activities. This includes our licensing authority.
• Fraud Prevention and Responsible Gaming Organizations: We may share information with organizations dedicated to preventing fraud, money laundering, and promoting responsible gaming.
• Affiliates and Group Companies: We may share your data with our corporate affiliates and group companies for internal administrative purposes, to provide joint services, or for business operational reasons.
• Business Transfers: In the event of a merger, acquisition, reorganization, 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 of your personal data.
• Professional Advisors: We may share your data with our professional advisors, such as lawyers, auditors, and consultants, in the course of providing their services to us.

We implement robust technical and organizational measures to protect your personal data from unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption: We use industry-standard encryption technologies, such as Secure Socket Layer (SSL) encryption, to protect data during transmission.
• Access Controls: Access to your personal data is restricted to authorized personnel who require it for their job functions, and they are bound by strict confidentiality obligations.
• Firewalls and Intrusion Detection Systems: We employ firewalls and intrusion detection systems to monitor and protect our networks from external threats.
• Regular Security 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 stated purposes.
• Employee Training: Our employees receive regular training on data protection and security best practices.

While we strive 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. We encourage you to also take steps to protect your account, such as using strong, unique passwords and not sharing your login details.

Depending on your jurisdiction and applicable data protection laws, you may have certain rights regarding your personal data. These rights may include:

• 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, 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 under certain conditions, for example, 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, where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data in certain situations, particularly where processing is based on legitimate interests 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 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, analyze site usage, and provide personalized content and advertising. Cookies are small text files stored on your device when you visit our website.

• Essential Cookies: These cookies are strictly necessary for the operation of our Services. They enable core functionalities like security, network management, and accessibility.
• Performance Cookies: These cookies collect information about how you use our Services, such as which pages you visit most often. This data helps us improve the performance of our website.
• Functionality Cookies: These cookies allow us to remember choices you make (such as your username, language, or region) and 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 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 usability of Spinko.

We retain your personal data 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 various factors, including:

• Legal and Regulatory Obligations: We are required by our licensing authority and anti-money laundering regulations to retain certain data for a minimum period (e.g., five to seven years after account closure).
• Contractual Obligations: Data necessary to provide our Services and enforce our Terms and Conditions.
• Dispute Resolution: Data may be retained to resolve disputes, enforce our agreements, and protect our legal rights.
• Business Needs: Data may be retained for internal analysis, service improvement, and fraud prevention, for periods consistent with these purposes.

Once your personal data is no longer required, we will securely delete or anonymize it in accordance with our data retention policies and applicable laws.

As Spinko operates globally, 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) that may not offer the same level of data protection. When we transfer your data internationally, we implement appropriate safeguards to ensure your personal data remains 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 for personal data by the European Commission.
• Implementing Standard Contractual Clauses (SCCs) approved by the European Commission, which provide contractual obligations for data protection.
• Relying on your explicit consent for specific transfers.

By using our Services, you understand that your information may be transferred to these third parties and countries.

Spinko's Services are 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 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 that a child has provided us with their personal data, please contact us immediately using the details in the "Contact Us" section.

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 email or through other communication channels. 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 the latest revisions were made. Your continued use of Spinko after any changes signifies your acceptance of the updated Privacy Policy.

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

• By Email: [email protected]
• Through Our Website: Via the "Contact Us" or "Support" section on the Spinko website.

We are committed to addressing your inquiries promptly and transparently.