Spin Games Privacy Policy – How We Handle Your Personal Data

1. Who We Are

This Privacy Policy is published by Spin Games, the operator of the online gaming and sports betting platform available at spingames.onl ("the Platform," "we," "us," or "our"). Spin Games acts as the data controller for all personal information collected through the Platform — meaning we determine why and how your data is processed.

This policy applies to all personal data collected when you visit spingames.onl, create a Spin Games account, make a deposit or withdrawal, place a bet, contact our customer support team, or interact with the Platform in any other way. It also covers personal data collected through our communications with you via email, WhatsApp, Telegram, and Live Chat.

If you have any questions about how Spin Games handles your data that are not addressed in this policy, please contact us directly at support@spingames.onl. We will respond within 48 hours on business days.

2. What Personal Data We Collect

Spin Games collects the following categories of personal data from players. We collect only what is genuinely needed — nothing more.

Spin Games does not collect or store full payment card numbers. Card transactions are processed by our certified payment processor and only masked card references (last 4 digits) are retained in our systems.

3. How We Collect Your Data

Spin Games collects personal data through the following channels:

• Directly from you: When you register an account, make a deposit or withdrawal, place a bet, complete a KYC verification, or contact our support team via any channel.
• Automatically during platform use: Our servers and analytics tools automatically record technical data such as your IP address, device information, browser type, and activity logs whenever you access spingames.onl.
• From payment processors: When you deposit or withdraw funds, our payment partners (Easypaisa, JazzCash, NayaPay, etc.) share transaction confirmation data with Spin Games to reconcile your account balance.
• From identity verification services: During KYC checks, Spin Games may use third-party identity verification providers to confirm the authenticity of documents you submit. These providers share verification results — not your raw document data — with us.
• Through cookies and similar technologies: See Section 9 for full details on how Spin Games uses cookies on the Platform.

4. Why We Use Your Personal Data

Spin Games uses your personal data for the following specific purposes. We will only process your data for a purpose that was either stated at the time of collection or is compatible with an original stated purpose.

• Account creation and management: Processing your registration, maintaining your account, and enabling you to log in securely to Spin Games.
• Payment processing: Facilitating your PKR deposits and withdrawals via Easypaisa, JazzCash, NayaPay, SadaPay, IBFT, and card channels — and reconciling your Spin Games account balance accurately.
• Identity verification (KYC): Confirming your identity, age (18+), and payment method ownership as required for responsible gaming and anti-money laundering compliance.
• Fraud detection and security: Monitoring account activity to detect and prevent fraud, bonus abuse, multi-accounting, and unauthorised access to your Spin Games account.
• Responsible gaming obligations: Identifying patterns of problem gambling behaviour, enforcing deposit limits and self-exclusion decisions, and providing responsible gaming tools effectively.
• Customer support: Handling your queries, complaints, and requests through Live Chat, email, WhatsApp, and Telegram — and maintaining records of those interactions for quality and audit purposes.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the Spin Games platform experience, fix technical issues, and develop new features Pakistani players genuinely want.
• Marketing communications (where consented): Sending promotional emails, SMS messages, or in-platform notifications about Spin Games bonuses, new game launches, and cricket betting features — only where you have explicitly opted in. See Section 12 for full details.
• Legal and regulatory compliance: Meeting our obligations under applicable anti-money laundering, data protection, and gaming regulations, including responding to lawful requests from regulatory authorities.

5. Legal Basis for Processing

Spin Games processes your personal data on the following legal grounds, depending on the specific purpose:

• Contractual necessity: Processing that is necessary to fulfil our agreement with you as a registered Spin Games player — including account management, payment processing, and bet settlement.
• Legal obligation: Processing required to comply with anti-money laundering legislation, age verification requirements, and any other applicable legal obligations.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement — where these interests are not overridden by your right to data privacy.
• Consent: Processing for direct marketing communications — only carried out where you have explicitly opted in. You may withdraw marketing consent at any time without affecting other aspects of your Spin Games account.

6. Sharing Your Personal Data

Spin Games does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We share your data only in the following limited circumstances:

• Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, IBFT banking partners, and card processing networks — strictly for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Licensed KYC verification services that confirm your CNIC authenticity and age during account verification — they receive only the data needed for the specific verification check.
• Game and technology providers: Third-party casino game software providers and live dealer studios whose games you play on the Spin Games platform. These providers may process your player ID and game activity data to deliver the game and record results.
• Anti-fraud and security services: Providers that help Spin Games detect and prevent fraud, bonus abuse, and multi-account violations — processing is limited to what is necessary for that specific purpose.
• Regulatory and legal authorities: Where Spin Games is legally required to share data with financial intelligence units, anti-money laundering authorities, or other regulatory bodies — we will comply with lawful requests in all circumstances.
• Corporate transactions: In the event of a merger, acquisition, or sale of the Spin Games business, your data may be transferred to the successor entity subject to the same privacy protections described in this policy.

All third-party processors used by Spin Games are bound by data processing agreements that prohibit them from using your data for any purpose other than the specific service they are providing to us.

7. Data Retention

Spin Games retains personal data only for as long as it is necessary for the purposes described in this policy, and in any case for no longer than required by applicable legal and regulatory obligations. The key retention periods are:

• Account and identity data: Retained for the duration of your active Spin Games account, plus a minimum of 5 years following account closure — as required for anti-money laundering compliance.
• Transaction records: All deposit and withdrawal records are retained for a minimum of 5 years from the date of the transaction.
• Gaming and betting history: Retained for the duration of your account plus 3 years, to support dispute resolution and regulatory audit requirements.
• KYC documents: Retained for the duration of your account and for 5 years following account closure.
• Support communications: Retained for 2 years from the date of the communication for quality assurance and dispute resolution purposes.
• Technical and session logs: Retained for 12 months from collection for security and fraud detection purposes.

When the retention period expires, Spin Games securely deletes or anonymises the relevant personal data. If you request deletion of your data earlier than the applicable retention period, we will delete or anonymise what we are legally permitted to — and retain only what we are legally required to keep, which we will explain clearly at the time of your request.

8. How We Protect Your Data

Spin Games takes the security of your personal data seriously. We implement industry-standard technical and organisational measures to protect your information against unauthorised access, disclosure, alteration, and destruction.

• Encryption in transit: All data transmitted between your device and the Spin Games platform is encrypted using TLS (Transport Layer Security) — the same technology used by banks and major payment platforms worldwide.
• Encrypted data storage: Sensitive personal and financial data stored in Spin Games systems is encrypted at rest using AES-256 encryption.
• Access controls: Internal access to your personal data is restricted on a strict need-to-know basis. Spin Games staff only access player data when it is necessary to perform their specific job function.
• Secure password storage: Your Spin Games account password is stored as a one-way cryptographic hash — even our own staff cannot see or recover your password. Always use a strong, unique password for your account.
• Regular security audits: Spin Games conducts regular security assessments of our platform infrastructure, including penetration testing, to identify and remediate vulnerabilities before they can be exploited.
• Fraud monitoring: Automated systems monitor account activity 24/7 to detect suspicious patterns that could indicate account compromise — and will alert or lock an account proactively if unusual activity is detected.

9. Cookies and Tracking Technologies

Spin Games uses cookies and similar tracking technologies on the Platform to ensure the website works correctly, to keep you logged in, and to understand how players interact with the Platform so we can improve it.

You can manage cookie preferences through your browser settings at any time. Note that disabling essential cookies will prevent the Spin Games platform from working correctly — you will not be able to log in or place bets. Disabling analytics or marketing cookies does not affect your ability to use the Platform.

10. Your Rights Over Your Personal Data

As a Spin Games player, you have the following rights regarding your personal data. To exercise any of these rights, contact us at support@spingames.onl with your request and your registered account details.

Spin Games will respond to all data rights requests within 30 days. For complex requests, we may extend this by a further 30 days — we will notify you if this applies. We may need to verify your identity before processing a data rights request, to ensure we are responding to the genuine account holder.

There is no charge for data rights requests. If a request is clearly unfounded or excessive in scope, we may charge a reasonable administrative fee or decline to process it — we will explain the reason clearly if either applies.

11. Children's Privacy

The Spin Games platform is intended exclusively for adults aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If you are under 18, you must not register an account or use the Spin Games platform in any way.

If Spin Games becomes aware that personal data has been collected from a player who is under 18, we will immediately close the account and delete all associated personal data. If you have reason to believe that a person under 18 has registered a Spin Games account, please contact us immediately at support@spingames.onl so we can take prompt action.

12. Marketing Communications

Spin Games may send you promotional communications about our bonuses, new games, cricket betting markets, and special offers — but only if you have explicitly consented to receive them. We do not send unsolicited marketing.

Marketing communications from Spin Games may be delivered via:

• Email to your registered address
• SMS to your registered mobile number
• In-platform notifications when you are logged in to your Spin Games account
• WhatsApp or Telegram messages, if you have initiated contact via these channels and opted in to promotional messages

You can withdraw your marketing consent at any time, without affecting your ability to use the Spin Games platform. To unsubscribe from marketing emails, use the unsubscribe link at the bottom of any Spin Games marketing email. To stop SMS messages, reply STOP to any Spin Games SMS. To update your notification preferences, visit your account settings or contact support@spingames.onl.

Please note that even if you opt out of marketing communications, Spin Games will still send you essential account communications — such as transaction confirmations, withdrawal processing updates, security alerts, and notifications required by our responsible gaming obligations. These are not marketing messages and cannot be turned off while your account remains active.

13. Third-Party Links and Services

The Spin Games platform may contain links to third-party websites or services. This Privacy Policy applies only to data processed by Spin Games directly — it does not cover the privacy practices of any third-party site or service you may navigate to from our platform.

If you click a link that takes you away from spingames.onl, we strongly recommend that you read the privacy policy of the destination website before providing any personal information. Spin Games is not responsible for the privacy practices or content of external sites, even if we have included a link to them for informational purposes.

14. Changes to This Privacy Policy

Spin Games may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or platform features. When we make material changes — changes that meaningfully affect how we collect or use your personal data — we will notify you via email and/or an in-platform notification at least 7 days before the changes take effect.

Minor updates, such as clarifications or corrections that do not change the substance of our data practices, may be made without advance notice beyond updating the "Last Updated" date at the top of this page. We recommend checking this page periodically to stay informed. The most current version of the Spin Games Privacy Policy will always be available at spingames.onl/privacy-policy.

Continued use of the Spin Games platform following the effective date of any updated policy constitutes your acceptance of the changes. If you do not accept an updated Privacy Policy, you should stop using the platform and may request account closure by contacting support@spingames.onl.

15. Contact and Data Requests

For any questions about this Privacy Policy, to exercise your data rights, or to report a privacy concern, please contact the Spin Games data team through any of the following channels:

• Email: support@spingames.onl — please include "Privacy Request" in your subject line for data rights requests.
• Live Chat: Available 24/7 from the Spin Games platform — our support team will direct your request to the relevant internal team.
• Response time: Privacy queries are responded to within 2 business days; formal data rights requests within 30 calendar days.

Spin Games is committed to resolving privacy concerns fairly and promptly. If you are not satisfied with our response to a privacy complaint, you retain the right to escalate the matter through applicable legal channels in your jurisdiction.