spinplay Privacy Policy

1. Data Controller

spinplay ("we," "us," or "our") is the data controller responsible for the personal data collected through the spinplay platform. As data controller, spinplay determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

spinplay has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with applicable data privacy laws. You may contact the DPO directly at the contact details provided in Section 14 of this policy.

2. Personal Data We Collect

2.1 Registration and Identity Data

When you create a spinplay account, we collect the following information:

• Full legal name as it appears on your government-issued ID
• Date of birth (for age verification — spinplay is strictly 21+ only)
• Residential address, including barangay, city/municipality, and province
• Email address and mobile number
• Username and encrypted password
• Nationality and country of residence

2.2 Identity Verification (KYC) Data

To comply with PAGCOR requirements and anti-money laundering regulations, spinplay collects:

• Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, UMID, PhilSys ID, driver's license)
• Proof of address documents (e.g., utility bills, bank statements dated within 90 days)
• Selfie photographs for identity matching purposes
• Source of funds documentation where required by regulatory thresholds

2.3 Financial and Transaction Data

spinplay collects and retains records of all financial transactions conducted through the platform, including:

• Deposit and withdrawal amounts, dates, and payment method references
• GCash account numbers, PayMaya account numbers, or bank account details used for transactions
• Transaction IDs and processing timestamps
• Bonus claims, wagering activity, and account balance history

2.4 Technical and Usage Data

When you access spinplay, we automatically collect certain technical data, including:

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Session duration, pages visited, and features used
• Game history, bet amounts, and session logs
• Referral source and marketing attribution data

2.5 Communications Data

If you contact spinplay via live chat, email, or any other channel, we retain records of those communications, including the content of messages, timestamps, and the resolution of any support requests.

3. How We Collect Your Data

spinplay collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in promotions.
• Automatically — through cookies, web beacons, and server logs when you access the spinplay platform.
• From third parties — including identity verification service providers, payment processors (such as GCash and PayMaya), fraud detection services, and regulatory databases where required by law.

4. How We Use Your Personal Data

spinplay uses your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your spinplay account.
• Identity verification: Confirming your age (21+), identity, and eligibility to use the platform in compliance with PAGCOR requirements.
• Transaction processing: Processing deposits, withdrawals, and bonus credits accurately and securely.
• Legal compliance: Meeting obligations under Philippine anti-money laundering laws (AMLA), PAGCOR regulations, and the Data Privacy Act.
• Fraud prevention: Detecting and preventing fraudulent activity, bonus abuse, money laundering, and unauthorized account access.
• Customer support: Responding to your inquiries, resolving disputes, and improving our support processes.
• Platform improvement: Analyzing usage patterns to improve spinplay's features, performance, and user experience.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates — subject to your communication preferences and applicable opt-out rights.
• Responsible gaming: Monitoring gaming behavior to identify potential problem gambling indicators and applying responsible gaming interventions where appropriate.

5. Legal Basis for Processing

spinplay processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act:

• Contractual necessity: Processing required to fulfill our obligations under the spinplay Terms & Conditions, including account management and transaction processing.
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA requirements, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

6.1 Service Providers

spinplay shares personal data with trusted third-party service providers who assist in operating the platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting services, fraud detection systems, and customer support platforms. All service providers are contractually bound to process data only on spinplay's instructions and to maintain appropriate security standards.

6.2 Regulatory Authorities

spinplay may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine authorities where required by law, court order, or regulatory directive. spinplay will notify affected Players of such disclosures where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of spinplay's business or assets, personal data held by spinplay may be transferred to the acquiring entity. Players will be notified of any such transfer and of any material changes to data processing practices that result from it.

6.4 No Sale of Data

spinplay does not sell, rent, or otherwise transfer your personal data to third parties for their own marketing or commercial purposes. Any data sharing is limited to what is necessary for the purposes described in this policy.

7. Data Retention

spinplay retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, as required by PAGCOR and AMLA regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Support communications: Retained for two (2) years from the date of the last interaction.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with spinplay's data disposal procedures.

8. Data Security

spinplay implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit
• AES-256 encryption for sensitive data at rest
• Two-factor authentication (2FA) for Player accounts and internal systems
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• Regular penetration testing and vulnerability assessments
• 24/7 security monitoring and intrusion detection systems
• Staff training on data privacy and security best practices

In the event of a personal data breach that poses a risk to your rights and freedoms, spinplay will notify the National Privacy Commission and affected Players within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular 16-03.

9. Cookies and Tracking Technologies

9.1 Types of Cookies Used

spinplay uses the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function. These cannot be disabled.
• Performance cookies: Collect anonymized data about how Players use spinplay to help us improve the platform.
• Functional cookies: Remember your preferences (such as language settings and login status) to personalize your experience.
• Marketing cookies: Used to deliver relevant promotional content. These are only set with your consent.

9.2 Managing Cookies

You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the spinplay platform. Detailed instructions for managing cookies in major browsers are available through your browser's help documentation.

10. Your Data Privacy Rights

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

• Right to be informed: The right to know what personal data spinplay collects and how it is used — as set out in this policy.
• Right of access: The right to request a copy of the personal data spinplay 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 spinplay's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used format for transfer to another service provider.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe spinplay has violated your data privacy rights.

To exercise any of these rights, please contact spinplay's Data Protection Officer using the contact details in Section 14. spinplay will respond to all data rights requests within thirty (30) days of receipt.

11. Children's Privacy

spinplay is strictly an adult platform. We do not knowingly collect personal data from individuals under the age of 21. If spinplay becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be closed. If you believe a minor has registered on spinplay, please contact us immediately at the details provided in Section 14.

12. International Data Transfers

spinplay's primary data processing infrastructure is located within the Philippines. Where personal data is transferred to service providers operating outside the Philippines (for example, cloud infrastructure providers or international payment processors), spinplay ensures that such transfers are subject to appropriate safeguards, including contractual data protection clauses that meet the standards required by the National Privacy Commission. spinplay does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards.

13. Updates to This Privacy Policy

spinplay may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or platform features. Material changes will be communicated to registered Players via email or a prominent notice on the spinplay platform at least seven (7) days before taking effect. The "Last Updated" date at the top of this policy indicates when the most recent revision was made. Your continued use of spinplay following any update constitutes your acceptance of the revised policy.

14. Contact and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or your personal data rights, please contact spinplay's Data Protection Officer: