Introduction

Spinarium collects and processes personal data in connection with account creation, gameplay, payments, customer support, and regulatory compliance. This Privacy and Data Management Policy explains what data we collect, why we collect it, how we use it, and the safeguards we implement to protect your information.

Data Controller and Scope

Spinarium acts as the data controller for the personal data processed in relation to our services. This policy applies to individuals who access or use Spinarium products and services, regardless of jurisdiction, where Spinarium operates and processes personal data on our platforms.

Information We Collect

• Personal identifiers: name, date of birth, home address, government-issued identification where required for verification.
• Contact details: email address, phone number, and any communications submitted via our channels.
• Account data: user name, login history, IP address, browser and device data, cookies and other tracking technologies, and activity logs.
• Financial and transaction data: deposits, withdrawals, bets, payment method details, and transaction timestamps.
• Verification documents: documents requested to verify identity, age, and payment methods, such as passport or identity card copies and proof of address.
• Correspondence and support records: interactions with customer support, web chats, emails, and contact forms.
• Survey and feedback data: responses to surveys or assessments conducted by Spinarium.
• Geolocation data and other information necessary to determine eligibility and prevent fraud or illegal activity.

How We Use Your Information

• To register and operate your account, authorize bets and handle payments in accordance with your instructions.
• To verify identity and age to comply with licensing, AML/CFT, and other regulatory requirements.
• To provide gaming and ancillary services and to maintain account settings and preferences.
• To communicate with you for support, updates, and notifications relevant to your account and services.
• To monitor transactions and activities for fraud prevention, abuse, and to detect suspicious or illegal activity.
• To analyze trends and improve Spinarium’s products and services, including research on user behavior in aggregated form.
• To provide marketing communications where you have provided consent or where allowed by law and you have not opted out.

Legal Bases for Processing

• Performance of a contract and necessary for providing Spinarium services.
• Compliance with legal and regulatory obligations, including licensing, AML/CFT, and gambling regulations.
• Legitimate interests in preventing fraud, ensuring security, and maintaining the integrity of the platform.
• Consent for direct marketing where applicable, with a clear mechanism to withdraw consent.

Marketing Communications

We may send promotional information about Spinarium products and services to individuals who opt in to receive such material. You may withdraw consent or opt out at any time through your account settings or by contacting customer support. We will honor any withdrawal of consent as soon as practicable in accordance with applicable law.

Data Recipients and Third-Party Processors

Spinarium may disclose or process your personal data with entities within our corporate group and with service providers who perform functions on our behalf, including:

• Payment processors and financial service providers.
• Customer support, hosting, analytics, and marketing service providers.
• Regulators, law enforcement, and other authorities as required by law or to protect legitimate interests.
• Third-party vendors engaged for identity verification, fraud prevention, and technical operations.

All third parties are contractually obligated to protect personal data and to process it only for the purposes disclosed by Spinarium.

International Transfers

Spinarium may transfer personal data to countries with different data protection regimes. We implement appropriate safeguards, including contractual measures and data protection standards, to ensure a level of protection substantially equivalent to that required by applicable law.

Data Retention

Spinarium retains personal data for the duration of the user’s account and for a minimum period required by law after account closure or last activity. In particular, personal data related to transactions and customer activity may be retained for at least five years from the date of last transaction or account closure to meet AML, auditing, and regulatory obligations. Anonymized or aggregated data may be retained longer for analytical purposes without identifying individuals.

Security of Your Data

We implement industry standard security measures to protect personal data, including encryption of data in transit and at rest, access controls, and regular security assessments. Account access requires a unique identifier and password, with optional two-factor authentication available to strengthen protection against unauthorized use. You are responsible for maintaining the confidentiality of your login credentials.

Your Rights

You have rights regarding your personal data, including:

• Access to confirm which data we hold about you and to obtain a copy.
• Rectification of inaccurate or incomplete data.
• Restriction or objection to processing in certain situations.
• Erasure of data where legally permissible, subject to applicable exemptions.
• Data portability where applicable, enabling you to receive your data in a structured, commonly used format.
• Withdrawal of consent for marketing at any time.

Requests should be submitted through your Spinarium account or by contacting our privacy team. We will respond in accordance with applicable law and provide guidance on any necessary verification steps.

Cookies and Tracking Technologies

We use cookies and similar technologies to operate the service, analyze usage, and tailor features. You may manage cookie settings in your browser, but disabling cookies may affect functionality. We classify cookies into strictly necessary, performance, functionality, and advertising categories and provide details in our cookie policy where applicable.

Children’s Privacy

Spinarium services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware of such data, we will take steps to delete it in a timely manner.

Data Breach Notification

In the event of a personal data breach, Spinarium will assess the risk to individuals and, where required by law, provide notification to affected individuals and competent authorities in a timely manner and in accordance with applicable regulations.

Changes to This Policy

Spinarium may update this policy from time to time. We will publish the replacement policy on our platform and, where required, notify you of material changes. Continued use of Spinarium services after such changes indicates your consent to the revised policy.

Contact Us

For questions about this policy or to exercise your data rights, contact Spinarium’s privacy team at [email protected].