Privacy Policy

Welcome to Spinit. This Privacy Policy outlines how Spinit, operated by [Company Name], collects, uses, stores, and protects your personal information when you use our website, services, and games. We protect your privacy and handle your data responsibly, complying with applicable data protection laws, including the General Data Protection Regulation (GDPR).

By accessing or using Spinit, you agree to the terms of this Privacy Policy. Read it carefully to understand our practices regarding your personal data. If you do not agree with the terms of this Privacy Policy, do not use our services.

We collect various types of information to provide and improve our services:

• Identity Data: This includes your first name, last name, date of birth, gender, and nationality. We require this for account creation and verification.
• Contact Data: Your email address, postal address, and telephone number. We use this to communicate with you regarding your account, promotions, and important updates.
• Financial Data: Details about your payment methods, such as bank account details, credit/debit card details, and other payment information. We do not store full credit card numbers, only a tokenized version for processing transactions.
• Transaction Data: Details about deposits, withdrawals, wagers, and other activities on your Spinit account.
• Technical Data: Your internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Spinit.
• Usage Data: Information about how you use our website, products, and services, including your gaming patterns, pages viewed, and feature interactions.
• Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties, and your communication preferences.
• Verification Data: Documents and information provided for Know Your Customer (KYC) and Anti-Money Laundering (AML) checks, such as copies of identification documents, utility bills, and source of wealth/funds information.

We use the information we collect for various purposes, primarily to provide and enhance your experience at Spinit:

• To register and manage your account, including verifying your identity and age.
• To process your transactions, including deposits and withdrawals.
• To provide you with access to our games and services.
• To communicate with you about your account, updates, and promotional offers, where you have consented.
• To monitor and improve the performance and functionality of our website and services.
• To detect and prevent fraudulent activities, money laundering, and other illegal activities.
• To comply with our legal and regulatory obligations, including licensing requirements.
• To conduct research and analysis to better understand our customers and improve our offerings.
• To personalize your experience on Spinit, tailoring content and offers to your preferences.
• To provide customer support and resolve any issues you encounter.

We process your personal data based on several legal grounds, as required by GDPR:

• Performance of a Contract: Processing is necessary for the performance of a contract to which you are a party, to provide you with our gaming services.
• Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject, such as anti-money laundering regulations, responsible gambling requirements, and licensing conditions.
• Legitimate Interests: Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms. Our legitimate interests include preventing fraud, improving our services, and ensuring network and information security.
• Consent: We obtain your explicit consent before sending you direct marketing communications or processing certain types of data, such as for specific analytics purposes, where other legal bases do not apply. You may withdraw your consent at any time.

We may share your personal data with third parties in certain 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, and customer support. These providers are contractually bound to protect your data and only use it for the purposes we specify.
• Regulatory and Law Enforcement Bodies: We may disclose your information to regulatory authorities, licensing bodies, law enforcement agencies, and other governmental bodies when legally required, or when we believe such disclosure is necessary to comply with legal obligations, protect our rights, or respond to legal processes.
• Auditors and Professional Advisors: We may share your data with our auditors, legal advisors, and other professional consultants for compliance, financial, or legal purposes.
• Affiliates and Group Companies: Your data may be shared with other entities within our corporate group for operational, analytical, and marketing purposes, always under strict confidentiality agreements.
• 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 as part of that transaction. We will notify you via email or a prominent notice on our website of any such change in ownership or control of your personal information.

We do not sell your personal data to third parties.

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

• Encryption of data in transit using SSL/TLS technology.
• Firewalls and intrusion detection systems to protect our networks.
• Access controls and authentication procedures for our systems.
• Regular security audits and vulnerability assessments.
• Employee training on data protection and privacy best practices.

While we protect your personal data, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security. We encourage you to also protect your account, such as using strong, unique passwords and keeping them confidential.

Under GDPR, you have several rights regarding your personal data:

• Right to Access: You may request a copy of the personal data we hold about you.
• Right to Rectification: You may request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure ('Right to be Forgotten'): You may request the deletion of your personal data, under certain conditions.
• Right to Restrict Processing: You may request that we restrict the processing of your personal data, under certain conditions.
• Right to Data Portability: You may receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller, under certain conditions.
• Right to Object: You may object to our processing of your personal data, under certain conditions, including for direct marketing purposes.
• Right to Withdraw Consent: Where we rely on your consent to process your personal data, you may withdraw that consent at any time.
• Right to Lodge a Complaint: You may lodge a complaint with a supervisory authority, particularly in the country where you reside, work, or where the alleged infringement of data protection laws occurred.

To exercise any of these rights, contact us using the details provided in the "Contact Us" section below. We may need to request specific information from you to confirm your identity and ensure your right to access your personal data, or to exercise any of your other rights.

Spinit 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 a website.

• Strictly Necessary Cookies: Essential for the website to function correctly, enabling basic features like page navigation and access to secure areas.
• Performance Cookies: Collect information about how visitors use our website, such as which pages are visited most often, to help us improve site functionality.
• Functional Cookies: Remember choices you make, such as your username, language, or region, to provide enhanced, more personal features.
• Targeting/Advertising Cookies: Used to deliver advertisements more relevant to you and your interests. They also 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. Disabling certain cookies may affect the functionality and your experience of Spinit.

We retain your personal data only as long as necessary to fulfill the purposes for which it was collected, including for satisfying any legal, accounting, or reporting requirements. Our retention periods are determined by considering the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and applicable legal requirements.

Typically, we retain customer account data for five years after the closure of your account, complying with anti-money laundering and gambling regulations, as well as for potential legal claims. After this period, your data will be securely deleted or anonymized.

As Spinit operates globally, your personal data may be transferred to, and stored at, a destination outside of the European Economic Area (EEA). This includes countries that may not offer the same level of data protection as within the EEA. When we transfer your data outside the EEA, we ensure appropriate safeguards are in place, such as using Standard Contractual Clauses approved by the European Commission, or ensuring the recipient country has been deemed to provide an adequate level of protection by the European Commission.

By using our services, you acknowledge and agree to such transfers, processing, and storage of your personal data as described in this policy.

Spinit is strictly for individuals aged 18 or over, or the legal age of majority in their jurisdiction, whichever is higher. We do not knowingly collect personal data from individuals under this age. If we become aware that we have inadvertently collected personal information from a child, we will delete that information as quickly as possible. If you believe we might have any information from or about a child, contact us.

We 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 new Privacy Policy on our website and, where appropriate, by sending you an email notification. 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 will indicate when the latest revisions were made.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, contact our Data Protection Officer:

Email: [email protected]

Postal Address: [Our Registered Office Address - to be filled in by Spinit]

We work with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to lodge a complaint with the relevant data protection authority.