spinlus Privacy Policy

1 Introduction

spinlus is committed to protecting the privacy and security of your personal data. We understand that when you share your information with us — whether during registration, KYC verification, or day-to-day use of the platform — you are placing trust in us to handle that data responsibly. This Policy sets out clearly and transparently how we honour that trust.

This Policy applies to all personal data collected by spinlus through the spinlus.org website, any associated mobile-optimised interfaces, and all communications between you and spinlus, including support interactions via email. It applies to all registered account holders and to visitors who browse spinlus.org without creating an account.

2 Personal Data We Collect

spinlus collects personal data from you in the following categories:

2.1 Registration Data

When you create a spinlus account, we collect: full legal name, date of birth, nationality, residential address, email address, and mobile number. This information is required to create and maintain your account and to verify your eligibility to use the platform.

2.2 Identity Verification (KYC) Data

To comply with our anti-money laundering (AML) obligations and to verify your age and identity, we collect copies of government-issued identification documents (such as your Philippine passport, SSS ID, UMID, driver's licence, or PhilSys national ID), proof of address documents, and proof of payment method ownership. This data is processed by our KYC compliance team and retained in accordance with applicable regulatory requirements.

2.3 Financial Data

We collect records of all deposits, withdrawals, and transactions conducted through your spinlus account, including payment method ident ifiers (e.g., GCash account name, bank account name) and transaction amounts in Philippine Peso (PHP). We do not store full card numbers; card payments are processed by PCI-DSS compliant payment processors who handle card data directly.

2.4 Usage & Technical Data

When you use spinlus, we automatically collect certain technical data, including: IP address, device type and operating system, browser type and version, pages visited and time spent, game session data (games played, bets placed, outcomes), and login timestamps. This data is used for security monitoring, fraud prevention, and platform improvement.

2.5 Communications Data

We retain records of all communications between you and spinlus, including support emails, live chat transcripts, and any correspondence relating to complaints or disputes. This data is retained to ensure quality of service and to maintain an accurate record of interactions.

2.6 Responsible Gaming Data

Where you use spinlus responsible gaming tools — such as deposit limits, loss limits, session reminders, or self-exclusion — we record and store the details of those elections. This data is used solely to enforce your responsible gaming preferences and is never used for marketing purposes.

3 How We Use Your Personal Data

spinlus uses your personal data for the following purposes:

spinlus does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by applicable AML or fraud prevention regulations.

4 Legal Basis for Processing

spinlus processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations, gaming regulations, and tax reporting obligations.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where these interests are not overridden by your data protection rights.
• Consent: Where we rely on your consent (e.g., for optional marketing communications), you may withdraw that consent at any time by contacting support or updating your account preferences.

5 Data Sharing & Disclosure

spinlus does not sell, rent, or trade your personal data. We share your data only in the following limited circumstances:

5.1 Service Providers

We share data with carefully selected third-party service providers who assist us in operating the spinlus platform, including KYC verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank, Visa/Mastercard networks), cloud hosting providers, and customer support platform providers. All service providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.

5.2 Regulatory & Law Enforcement Authorities

spinlus will disclose personal data to Philippine regulatory authorities (including PAGCOR and the Anti-Money Laundering Council), law enforcement agencies, and courts where required to do so by applicable law, court order, or regulatory direction. We will notify you of such disclosures where legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of spinlus's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material changes to this Privacy Policy that result from it.

6 Data Security

spinlus implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction:

• 256-bit SSL/TLS encryption on all data in transit between your device and spinlus servers
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial records
• Multi-factor authentication available for all spinlus accounts and mandatory for all internal staff access to production systems
• Regular penetration testing and vulnerability assessments conducted by independent security firms
• Role-based access controls ensuring that staff can only access personal data necessary for their specific job function
• 24/7 security monitoring with automated alerts for suspicious access patterns or anomalous activity

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, spinlus will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay, in accordance with the requirements of the Philippine Data Privacy Act.

7 Data Retention

spinlus retains your personal data for the following periods:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data destruction procedures.

8 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by spinlus:

• Right to be informed: The right to be told how your personal data is being collected and used — which this Privacy Policy fulfils.
• Right of access: The right to request a copy of the personal data spinlus holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to our legal retention obligations.
• Right to object: The right to object to processing of your personal data for direct marketing or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at the email address listed in Section 13 of this Policy. We will respond to all verified data rights requests within 15 business days of receipt.

9 Cookies & Tracking Technologies

spinlus uses cookies and similar technologies (such as local storage and session tokens) to operate and improve the platform. The following categories of cookies are used:

• Strictly necessary cookies: Required for the platform to function, including session authentication tokens and security cookies. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations.
• Analytics cookies: Collect aggregated, anonymised data about how users interact with spinlus to help us improve the platform. No personally identifiable information is included in analytics data.

spinlus does not use third-party advertising or retargeting cookies. You can manage or disable non-essential cookies through your browser settings at any time. Note that disabling strictly necessary cookies will prevent you from logging in to your spinlus account.

10 Children's Privacy

spinlus is strictly an adult platform. We do not knowingly collect personal data from persons under 21 years of age. The minimum age to register and use spinlus is 21 years, in accordance with applicable Philippine gaming regulations. If spinlus becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended, all data will be deleted, and any funds held will be handled in accordance with applicable regulatory requirements.

If you believe that a person under 21 has registered a spinlus account, please contact us immediately at the email address in Section 13.

11 International Data Transfers

spinlus primarily stores and processes your personal data within the Philippines. Where data is transferred to service providers located outside the Philippines (for example, cloud infrastructure providers), spinlus ensures that appropriate safeguards are in place to protect your data, including contractual data processing agreements that impose data protection standards equivalent to those required under Philippine law.

spinlus will not transfer your personal data to any jurisdiction that does not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

12 Updates to This Privacy Policy

spinlus reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform features. When we make material changes to this Policy, we will notify registered account holders by email and display a prominent notice on the spinlus platform for a period of not less than 30 days prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically. Your continued use of spinlus following notification of changes constitutes your acceptance of the revised Policy.

13 Contact & Data Protection Officer

spinlus has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and with the Philippine Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact our DPO:

Data Protection Officer — spinlus
Email: [email protected]

Please include "Privacy Request" or "DPO Enquiry" in the subject line of your email, along with your registered account username and a clear description of your request. We aim to acknowledge all privacy-related enquiries within 2 business days and to resolve them within 15 business days.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC).