spinolus Privacy Policy

1. Introduction and Scope

spinolus ("spinolus," "we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who access or use the spinolus platform at spinolus.one (the "Platform"). This Privacy Policy ("Policy") describes how spinolus collects, processes, stores, shares, and protects personal information in connection with the Services we provide to registered members and visitors in the Philippines and elsewhere.

This Policy applies to all personal data processed by spinolus in connection with your use of the Platform, including data collected through the spinolus website, account registration, gameplay activity, customer support interactions, and payment transactions. It should be read together with the spinolus Terms & Conditions and Responsible Gaming Policy.

By registering a spinolus account, accessing the Platform, or otherwise providing your personal information to spinolus, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the spinolus platform.

spinolus processes personal data in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC").

2. Information We Collect

spinolus collects personal information that is necessary to provide you with a safe, secure, and personalized gaming experience. The categories of personal data we collect include:

spinolus does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by applicable law or regulatory obligation (for example, problem gambling self-exclusion records).

3. How We Use Your Information

spinolus uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and administer your spinolus account, including processing your spinolus Login credentials and verifying your identity.
• Service Delivery: To provide you with access to spinolus games, live casino, sports betting, slots, bingo, and all other platform features.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and DragonPay, and to maintain accurate financial records in Philippine Peso (PHP).
• Regulatory Compliance: To fulfill our obligations under the Data Privacy Act of 2012, anti-money laundering regulations, and applicable Philippine gaming regulations, including age verification (21+) and Know Your Customer (KYC) requirements.
• Responsible Gaming: To monitor gameplay patterns, identify potential problem gambling behavior, and administer responsible gaming tools such as deposit limits, session reminders, and self-exclusion.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 support team.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other prohibited conduct on the spinolus platform.
• Platform Improvement: To analyze usage patterns, conduct internal research, and improve the spinolus platform experience for Filipino players.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where permitted by applicable law. You may opt out of marketing communications at any time through your account settings.

4. Legal Basis for Processing

spinolus processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications or enabling optional platform features.
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and spinolus, including account registration, game access, and payment processing.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to spinolus, including KYC verification, AML reporting, and age verification requirements.
• Legitimate Interests: Where processing is necessary for the legitimate interests of spinolus, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and freedoms.

Where spinolus relies on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing and Disclosure

spinolus does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and DragonPay, for the purpose of processing your deposits and withdrawals.
• Game Content Providers: Third-party game studios and live casino operators whose games are available on the spinolus platform, to the extent necessary for game delivery and fairness verification.
• Identity Verification Services: Third-party KYC and AML compliance providers engaged by spinolus to verify your identity and comply with regulatory requirements.
• Regulatory Authorities: Philippine gaming regulators, the National Privacy Commission, law enforcement agencies, and other government bodies, where disclosure is required by law or court order.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers engaged by spinolus to operate and secure the platform.
• Professional Advisors: Legal counsel, auditors, and other professional advisors engaged by spinolus in connection with the operation of the platform.

All third parties with whom spinolus shares personal data are required to process such data in accordance with applicable data protection laws and are prohibited from using your data for any purpose other than those specified by spinolus.

6. Cookies and Tracking Technologies

spinolus uses cookies and similar tracking technologies to enhance your experience on the platform, maintain your session state, and collect analytical data about platform usage. The types of cookies used by spinolus include:

• Strictly Necessary Cookies: Essential for the operation of the spinolus platform, including maintaining your spinolus Login session and enabling core platform functionality. These cookies cannot be disabled.
• Performance and Analytics Cookies: Used to collect anonymized data about how visitors use the spinolus platform, helping us identify areas for improvement.
• Functionality Cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats on the spinolus platform.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the spinolus platform. For more information about the specific cookies used by spinolus, please contact our support team.

7. Data Retention

spinolus retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account Data: Retained for the duration of your spinolus account and for a period of five (5) years following account closure, in accordance with applicable AML and gaming regulatory requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• KYC and Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required for dispute resolution purposes.
• Technical and Usage Data: Retained for up to two (2) years from the date of collection, after which it is anonymized or deleted.

Upon expiry of the applicable retention period, spinolus will securely delete or anonymize your personal data in accordance with its data disposal procedures.

8. Data Security

spinolus implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the spinolus platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of the spinolus platform.
• Multi-factor authentication options for spinolus Login to protect your account from unauthorized access.
• 24/7 monitoring of platform systems for suspicious activity and potential security incidents.

9. Your Rights as a Data Subject

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by spinolus:

• Right to be Informed: You have the right to be informed of how your personal data is being collected and processed by spinolus, as set out in this Privacy Policy.
• Right to Access: You have the right to request a copy of the personal data spinolus holds about you, along with information about how it is being used.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data spinolus holds about you. You may update most account information directly through your spinolus account settings.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to spinolus's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on spinolus's legitimate interests.
• 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 Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe spinolus has violated your data privacy rights.

To exercise any of the above rights, please contact the spinolus Data Privacy Officer at [email protected]. spinolus will respond to all verified data subject requests within thirty (30) days of receipt, in accordance with the requirements of the Data Privacy Act of 2012.

10. Children's Privacy

The spinolus platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. spinolus does not knowingly collect personal data from individuals under the age of 21. If spinolus becomes aware that personal data has been collected from an individual under the age of 21, the relevant account will be immediately suspended and the personal data will be deleted in accordance with spinolus's underage gaming policy.

If you are a parent or guardian and believe that your child has registered a spinolus account or provided personal data to spinolus, please contact our support team immediately at [email protected] so that we can take appropriate action.

11. Changes to This Privacy Policy

spinolus reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, spinolus will notify registered members via email or through a prominent notice on the spinolus platform. The date of the most recent revision is indicated at the top of this page.

Your continued use of the spinolus platform following the publication of a revised Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically to stay informed about how spinolus protects your personal data.

12. Contact and Data Inquiries

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by spinolus, please contact our Data Privacy Officer:

• Email: [email protected]
• Response Time: Within 30 days for formal data subject requests; within 24 hours for general support inquiries.
• Regulatory Authority: National Privacy Commission of the Philippines — for complaints that cannot be resolved directly with spinolus.

Our support team is available 24/7 and is familiar with the needs of Filipino players across Metro Manila, Cebu, Davao, Quezon City, Makati, and the rest of the Philippines.