Privacy Policy

1. Who We Are

spinsph ("we," "us," or "our") operates the online gaming platform accessible at spinsph.app, providing casino games, slots, bingo, and related entertainment services to players in the Philippines. As the operator of this Platform, spinsph acts as the data controller responsible for the personal information you provide when registering, playing, or otherwise interacting with our services.

This Privacy Policy applies to all users of the spinsph Platform, including registered players, visitors browsing the site without an account, and any individual who contacts our support team. By using the Platform, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

spinsph collects personal data through several channels. The categories of information we may collect include:

• Registration data: Full name, date of birth, nationality, residential address, email address, and mobile number provided when creating your spinsph account.
• Identity verification (KYC) data: Government-issued identification documents (e.g., Philippine passport, SSS ID, driver's licence, PhilSys national ID), selfie photographs, and proof of address documents submitted to comply with anti-money laundering (AML) and know-your-customer (KYC) obligations.
• Financial data: Payment method details (e.g., GCash mobile number, bank account details for BPI, BDO, Metrobank, UnionBank, Landbank, or debit card information), transaction history, deposit and withdrawal records.
• Gaming activity data: Game session logs, wager amounts, win/loss records, bonus usage, and responsible gaming tool settings.
• Technical data: IP address, device type, browser type and version, operating system, referring URLs, and session timestamps collected automatically when you access the Platform.
• Communications data: Records of your interactions with our customer support team, including live chat transcripts and email correspondence.
• Preference data: Language preferences, marketing communication opt-in/opt-out status, and notification settings.

We collect only the minimum personal data necessary for the purposes described in this Policy. We do not collect sensitive personal information beyond what is required for identity verification and regulatory compliance.

3. How We Use Your Information

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

• Account management: To create, maintain, and administer your spinsph player account, including processing deposits and withdrawals.
• Identity verification: To verify your identity and age (21+) in compliance with Philippine gaming regulations and AML/KYC requirements.
• Service delivery: To provide access to games, process bets, calculate and pay out winnings, and deliver the full range of spinsph Platform features.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, money laundering, account takeovers, and other illegal or prohibited activities.
• Regulatory compliance: To fulfil our obligations under applicable Philippine laws, PAGCOR regulations, and AML/CTF (counter-terrorism financing) requirements, including reporting obligations.
• Responsible gaming: To monitor gaming patterns, enforce self-exclusion requests, apply deposit limits, and identify players who may be at risk of problem gambling.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided your consent or where we have a legitimate interest to do so. You may opt out at any time.
• Platform improvement: To analyse usage patterns, conduct A/B testing, and improve the functionality, performance, and user experience of the spinsph Platform.

4. Legal Basis for Processing

spinsph processes your personal data on the following legal grounds under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you agreed to upon registration, including account management and payment processing.
• Legal obligation: Processing required to comply with applicable laws, including PAGCOR licensing conditions, AML/KYC regulations, and tax reporting requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where our legitimate interests are not overridden by your rights and freedoms.
• Consent: Processing for direct marketing communications, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Sharing of Personal Data

spinsph does not sell or rent your personal data to third parties. We may share your information with the following categories of recipients only to the extent necessary:

• Payment processors: GCash, PayMaya/Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank) to process deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers who assist in verifying your identity documents and age.
• Game software providers: Licensed game studios whose titles are hosted on the spinsph Platform, to the extent required for game operation and audit purposes.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies where disclosure is required by law or court order.
• IT and infrastructure providers: Cloud hosting, cybersecurity, and analytics service providers operating under strict data processing agreements that prohibit independent use of your data.

All third-party service providers engaged by spinsph are contractually required to implement appropriate technical and organisational security measures and to process personal data only in accordance with our instructions.

6. Cookies and Tracking Technologies

The spinsph Platform uses cookies and similar tracking technologies to enhance your experience and support Platform operations. The types of cookies we use include:

• Essential cookies: Required for the Platform to function, including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations.
• Analytics cookies: Collect anonymised data about how players use the Platform to help us improve performance and user experience.
• Marketing cookies: Used to deliver relevant promotional content within the spinsph Platform. We do not use third-party advertising networks.

You may manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may affect Platform functionality.

7. Data Retention

spinsph retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law. Specifically:

• Account and transaction records are retained for a minimum of five (5) years following account closure, in compliance with Philippine AML regulations.
• KYC documentation is retained for the period required by PAGCOR licensing conditions and AML/CTF regulations.
• Customer support communications are retained for two (2) years following resolution of the relevant matter.
• Marketing preference records are retained until you withdraw consent or request deletion, subject to any overriding legal retention obligations.

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

8. Data Security

spinsph implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the spinsph Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Multi-factor authentication for administrative access to systems containing personal data.

In the event of a personal data breach that poses a risk to your rights and freedoms, spinsph will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012.

9. Your Rights as a Data Subject

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

• Right to be informed: The right to know what personal data we collect and how it is used — which this Privacy Policy fulfils.
• Right of access: The right to request a copy of the personal data we hold 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 purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used format.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at the details provided in Section 12. We will respond to all verified requests within thirty (30) days.

10. Children and Minors

The spinsph Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine law governing casino-style gambling. spinsph does not knowingly collect personal data from individuals under 21 years of age. If we become aware that personal data has been collected from a minor, we will immediately suspend the relevant account, delete the data, and return any deposited funds in accordance with applicable regulations.

If you believe that a minor has registered on the spinsph Platform, please contact our support team immediately so that we can take appropriate action.

11. Changes to This Policy

spinsph reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via email or in-platform notification at least seven (7) days prior to taking effect. The date of the most recent revision is displayed at the top of this page. Your continued use of the spinsph Platform following the effective date of any revision constitutes your acceptance of the updated Privacy Policy.

12. Contact and Data Enquiries

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

• Email: [email protected]
• Live Chat: Available 24/7 via the spinsph Platform
• Response Time: We aim to respond to all data privacy requests within 30 days

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you are not satisfied with our response to your data privacy concern.