Privacy Notice

Scope and data controller

Spinanga acts as the data controller for personal data collected in connection with Spinanga Services. This Privacy Notice governs personal data processed through Spinanga websites, mobile applications, games, and related features that link to this policy or do not have a separate privacy policy. If you have questions about how your data is handled, contact the Spinanga privacy team via the in‑app help center or the official support channels within Spinanga Services.

Categories of personal data we collect

  • Contact and identity data: name, residential address, email address, telephone number, date of birth, and government-issued identifiers as required for account verification.
  • Account and activity data: login history, registered username, transaction records, bets placed, winnings, bonuses, and interactions with Spinanga services.
  • Technical data: IP address, device identifiers, browser and operating system information, and geolocation data derived from your device or network.
  • Financial data: payment methods, bank account or card details supplied for processing transactions, source of funds, and withdrawal history.
  • Marketing and communications data: preferences for receiving marketing communications, responses to surveys, and correspondence with Spinanga support.
  • Behavioural data: information generated by your activity within Spinanga Services, including game preferences and engagement metrics.

How we use personal data

  • To create and manage your Spinanga account, verify your identity, and prevent fraud or impersonation.
  • To provide, maintain, and improve Spinanga Services, including game delivery, payments, and customer support.
  • To comply with legal and regulatory obligations, including anti‑money laundering (AML) and know-your-customer (KYC) requirements.
  • To communicate with you about account matters, service updates, and requested information.
  • To personalise your experience and tailor content and offers, subject to your consent or legitimate interests where permitted by law.
  • To monitor for responsible gaming and support mitigation of problem gambling, including risk assessments and related interventions.

Legal bases for processing

  • Contractual necessity: processing is required to perform the service you request, maintain your account, and deliver Spinanga Services.
  • Legitimate interests: processing to improve services, enhance security, and develop new features, provided such interests do not override your rights.
  • Regulatory obligations: AML/KYC, gambling licensing, and other applicable legal requirements.
  • Consent: where required for direct marketing or for processing based on consent, you may withdraw consent at any time.

Sharing and international transfers

We may share your personal data with trusted service providers acting on our behalf (for example, payment processors, IT services, customer support, and fraud prevention) under contract and with safeguards that protect your data consistent with this policy. We may disclose information to regulators or law enforcement as required by applicable law. Where Spinanga transfers data to jurisdictions outside your residence, such transfers will be subject to appropriate safeguards designed to protect your information in accordance with applicable data protection laws.

Data retention

Spinanga retains personal data only for as long as necessary to fulfill the purposes described in this Notice and to comply with legal, regulatory, and contractual obligations. Transactional data (including bets, payments, and related records) is retained for a minimum period of five (5) years. Other data is retained for the period necessary to manage the ongoing relationship, resolve disputes, and meet applicable legal obligations, after which it will be securely deleted or anonymised.

Your rights

  • Access: you may request access to your personal data held by Spinanga.
  • Rectification: you may request correction of inaccurate or incomplete data.
  • Erasure: you may request deletion of personal data where there is no lawful basis for its continued processing.
  • Restriction: you may request temporary suspension of processing in certain circumstances.
  • Data portability: you may request a portable copy of your personal data in a structured, commonly used, and machine-readable format where applicable.
  • Objection and withdrawal of consent: you may object to processing based on legitimate interests or withdraw consent where processing is consent-based.
  • Complaint: you may lodge a complaint with a supervisory authority in relation to our handling of your data.

Profiling and automated processing

Spinanga may perform profiling and automated checks to assess risk, AML compliance, and to personalise service delivery. Examples include evaluation of IP addresses, device data, and behavioural patterns. Final decisions affecting your account and services are made by human operators; no decisions with legal or similarly significant effects are made solely by automated processing without human review.

Cookies and tracking technologies

We use cookies and similar technologies to deliver Spinanga Services, analyse usage, and support marketing efforts. You may configure your cookie preferences through in-service controls, and we may rely on consent or legitimate interests as the lawful basis for certain cookies where required by applicable law.

Security

Spinanga implements industry‑standard security measures to protect personal data, including encryption in transit using secure transmission protocols and encryption at rest on data stores, access controls, and regular security assessments. Personal data is stored in systems with restricted access and appropriate monitoring to prevent unauthorised processing.

Age restriction and children’s privacy

Spinanga services are available only to individuals who are at least eighteen (18) years old. We implement age verification measures as part of account opening and ongoing monitoring. We do not knowingly collect personal data from individuals under the minimum age without verifiable consent or as required by law.

Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our processing activities or legal obligations. If we make material changes, we will provide clear notice within Spinanga Services and update the effective date at the top of the notice.

Contact us

If you have questions, requests, or concerns regarding your personal data or this Privacy Notice, please contact Spinanga’s privacy team via the in‑app help center or through the official support channels within Spinanga Services. You may also request information about the processing of your data or lodge a complaint with the relevant data protection authority as applicable.