Privacy Policy

Spinbet Online Casino — Privacy Policy

Last Updated: 2024

1. Introduction and Overview

Spinbet is an online casino and iGaming platform operated under a license issued by the Government of Curacao. This Privacy Policy governs the collection, use, storage, processing, and disclosure of personal information obtained from users who access or interact with the Spinbet platform, including but not limited to its website, mobile applications, and any associated digital services. This document has been prepared in accordance with applicable data protection principles, the Privacy Act 1988 (Cth) of Australia, the Australian Privacy Principles (APPs) contained in Schedule 1 of that Act, and relevant anti-money laundering, counter-terrorism financing, and responsible gambling regulatory obligations applicable to Spinbet’s operations.

By registering an account, accessing the platform, or using any service offered by Spinbet, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy. If you do not agree with any provision of this policy, you must discontinue use of the platform immediately. Spinbet reserves the right to update this Privacy Policy at any time, and material changes will be communicated to registered users through appropriate channels.

2. Who We Are

Spinbet is an online casino operator licensed and regulated under the Curacao gaming license framework. The platform provides a range of iGaming services including online casino games, live dealer experiences, pokie machines, table games, and other wagering products. All data processing activities described in this Privacy Policy are carried out by Spinbet or its authorised third-party processors acting on its behalf and under its instructions.

3. Information We Collect

Spinbet collects various categories of personal information in the course of operating its platform and fulfilling its legal and regulatory obligations. The categories of data collected include the following:

• Registration data, including full legal name, date of birth, residential address, email address, phone number, and username chosen at account creation
• Government-issued identification documents, including passport copies, national identity cards, and driver’s license details, collected as part of mandatory Know Your Customer procedures
• Payment and financial information, including bank account details, credit and debit card information, e-wallet account identifiers, and transaction history associated with deposits and withdrawals
• Identity verification data collected through third-party verification partners, including responses to identity checks, source of funds documentation, and proof of address documents
• Technical and usage data, including IP addresses, device identifiers, browser type and version, operating system, session duration, pages visited, clickstream data, and interaction logs
• Cookie data and tracking information collected automatically when you use the platform, as further described in the Cookie Policy section of this document
• Communications data, including records of correspondence between you and Spinbet’s customer support team, whether by email, live chat, or other channels
• Responsible gambling data, including self-exclusion requests, deposit limits, session limits, and any information provided during responsible gambling assessments

Spinbet does not knowingly collect personal data from individuals under the age of eighteen years. The platform employs age verification measures to prevent minors from accessing its services.

4. Purpose of Data Collection and Processing

Spinbet processes personal data for specific, lawful purposes directly related to the operation of its iGaming platform and compliance with applicable legal obligations. The purposes for which data is collected and processed include the following:

• Account management and administration, including creating and maintaining user accounts, verifying account holder identity, processing login requests, and facilitating access to platform services
• Know Your Customer procedures, conducted in accordance with anti-money laundering requirements and Curacao licensing obligations, to verify the identity of users before allowing withdrawals or high-value transactions
• Anti-money laundering compliance and counter-terrorism financing obligations, including monitoring transaction patterns, conducting enhanced due diligence where required, and filing reports with relevant authorities as mandated by law
• Fraud prevention and detection, including analysis of usage patterns, IP address monitoring, device fingerprinting, and cross-referencing of user data against fraud databases and sanctions lists
• Payment processing and financial transaction management, including facilitating deposits, processing withdrawal requests, and maintaining accurate financial records
• Marketing communications, where users have provided consent, including sending promotional offers, bonus notifications, newsletters, and personalised gaming recommendations via email, SMS, or push notifications
• Customer support and dispute resolution, including responding to queries, investigating complaints, and maintaining records of communications for quality assurance purposes
• Responsible gambling obligations, including enforcing self-exclusion arrangements, monitoring for signs of problem gambling behaviour, and providing access to responsible gambling tools
• Legal and regulatory compliance, including responding to lawful requests from regulatory authorities, law enforcement agencies, and courts of competent jurisdiction
• Platform improvement and analytics, including using aggregated and anonymised data to analyse platform performance, user behaviour trends, and service quality

5. Legal Basis for Processing

Spinbet processes personal data on the following legal bases:

• Performance of a contract, where processing is necessary to provide the services requested by the user upon registration and account creation
• Compliance with legal obligations, where processing is required to meet anti-money laundering, KYC, tax reporting, and other regulatory requirements
• Legitimate interests of Spinbet, where processing is necessary for fraud prevention, platform security, and business operations, provided such interests are not overridden by the rights and interests of the data subject
• Consent of the data subject, where the user has explicitly agreed to processing for purposes such as direct marketing communications

6. Data Sharing and Disclosure

Spinbet may share personal information with third parties in the following circumstances:

• Payment service providers and financial institutions, to facilitate the processing of deposits and withdrawals made through the platform
• Identity verification and KYC service providers, who assist Spinbet in verifying the identity of users and conducting due diligence checks as required by applicable regulations
• Anti-fraud and risk management partners, including third-party services that assist in detecting and preventing fraudulent activity, money laundering, and other financial crimes
• Regulatory authorities and licensing bodies, including the Curacao gaming authority and any other competent regulatory body that has lawful authority to request disclosure of user data
• Law enforcement agencies and government bodies, where Spinbet is required by law, court order, or legal process to disclose personal information
• Technology and platform service providers, including cloud hosting providers, software vendors, and IT support partners who process data on behalf of Spinbet under binding data processing agreements
• Professional advisors, including legal counsel, auditors, and compliance consultants, where disclosure is necessary for the provision of professional services

Spinbet does not sell personal data to third parties for commercial purposes unrelated to the operation of the platform. All third-party recipients of personal data are required to maintain appropriate security standards and to use the data only for the purposes for which it was disclosed.

7. International Data Transfers

Spinbet operates in a global environment and may transfer personal data to third-party service providers or partners located outside of Australia. Where such transfers occur, Spinbet takes appropriate measures to ensure that the data is protected in accordance with applicable data protection standards, including the execution of contractual safeguards and ensuring that recipient countries or organisations provide an adequate level of data protection.

8. Data Retention

Spinbet retains personal data for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes or enforce agreements. In particular:

• Account data and KYC documentation are retained for a minimum of five years following the closure of a user account, in accordance with anti-money laundering regulatory requirements
• Financial transaction records are retained for a minimum of seven years to satisfy tax and financial reporting obligations
• Technical logs and usage data may be retained for shorter periods, typically between twelve and twenty-four months, depending on the nature of the data and the purpose for which it was collected
• Marketing consent records are retained for as long as the consent remains valid or until the user withdraws consent

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents identification of the individual.

9. User Rights

Users whose personal data is processed by Spinbet have the following rights under applicable data protection law:

• The right to access personal data held by Spinbet, including the right to request a copy of the information and to receive details about how it is being processed
• The right to request correction of inaccurate or incomplete personal data held on file
• The right to request deletion of personal data in circumstances where it is no longer necessary for the purposes for which it was collected, subject to Spinbet’s legal obligations to retain certain data
• The right to restrict processing of personal data in certain circumstances, including where the accuracy of the data is contested or where the user objects to processing based on legitimate interests
• The right to object to processing of personal data for direct marketing purposes, which may be exercised at any time by following the unsubscribe instructions in marketing communications or by contacting Spinbet directly
• The right to data portability, where technically feasible, allowing users to receive their personal data in a structured, commonly used, and machine-readable format
• The right to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out prior to withdrawal

To exercise any of the above rights, users may submit a written request to Spinbet through the contact mechanisms provided on the platform. Spinbet will respond to requests within a reasonable timeframe in accordance with applicable law.

10. Cookie Policy

Spinbet uses cookies and similar tracking technologies on its platform to ensure proper functionality, enhance user experience, and collect analytical data. Cookies are small text files stored on a user’s device when they access the platform.

The following categories of cookies are used:

• Essential cookies, which are strictly necessary for the operation of the platform, including cookies that enable login sessions, maintain account security, and ensure the correct display of platform content
• Analytical and performance cookies, which collect information about how users interact with the platform, including pages visited, time spent on the platform, and error messages encountered, for the purpose of improving platform performance and user experience
• Functional cookies, which allow the platform to remember user preferences such as language settings and display options
• Marketing and targeting cookies, which may be used to deliver personalised promotional content and to measure the effectiveness of marketing campaigns, where the user has provided consent

Users may manage their cookie preferences through the cookie consent tool available on the platform or through their browser settings. Disabling essential cookies may affect the functionality of the platform.

11. Data Security

Spinbet implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include encryption of data in transit and at rest, access controls limiting data access to authorised personnel, regular security assessments, and incident response procedures. In the event of a data breach that is likely to result in a risk to the rights and freedoms of individuals, Spinbet will notify affected users and relevant authorities in accordance with applicable notification obligations.

12. Responsible Gambling and Data Processing

Spinbet is committed to promoting responsible gambling and takes its obligations in this area seriously. Personal data collected in connection with responsible gambling tools, including self-exclusion requests, deposit limits, and problem gambling assessments, is processed for the purpose of protecting the wellbeing of users and fulfilling Spinbet’s duty of care obligations. This data is treated with the highest level of confidentiality and is not used for marketing or commercial purposes.

13. Changes to This Privacy Policy

Spinbet reserves the right to amend this Privacy Policy at any time. Where changes are material, users will be notified through the platform or by direct communication. Continued use of the platform following notification of changes constitutes acceptance of the updated policy. Users are encouraged to review this Privacy Policy periodically to remain informed of how their personal data is being processed.

14. Contact Information

Users wishing to exercise their data rights, raise concerns about data processing practices, or make enquiries regarding this Privacy Policy may contact Spinbet through the official contact channels provided on the platform website. Spinbet is committed to addressing all data-related enquiries in a timely and transparent manner.