spinco Casino Privacy Policy

Introduction

spinco is a premium online casino platform serving Filipino players across Manila, Cebu, Davao, Quezon City, Makati, and the entire Philippine archipelago. We understand that when you sign up with spinco and share your personal information with us, you are placing real trust in our platform — and that trust is something we do not take lightly.

This Privacy Policy sets out in clear, plain language exactly how spinco handles your personal data. It covers what information we collect during registration and gameplay, the purposes for which that data is used, the circumstances under which it may be shared with third parties, and your rights with respect to your own data under applicable Philippine law, including the Data Privacy Act of 2012 (Republic Act No. 10173).

This Policy applies to all personal data collected through the spinco website at spinco.bio, any associated mobile-optimised interfaces, and any communications between you and spinco including support chat, email, and promotional messaging. It should be read together with the spinco Terms & Conditions, which form the broader contractual framework governing your use of the platform.

If you have any questions about this Policy or how spinco handles your data, you are welcome to contact our support team at any time via live chat on the platform.

Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection principles, spinco acts as the data controller in respect of all personal data collected from players on the spinco platform. As data controller, spinco is responsible for determining the purposes and means of processing your personal data and for ensuring that such processing is carried out lawfully, fairly, and transparently.

spinco's designated data privacy point of contact can be reached through the support channels available on the platform. For formal written data privacy enquiries, you may contact spinco at the email address provided in Section 14 of this Policy.

Personal Data We Collect

spinco collects personal data from you in three primary ways: information you provide directly during registration and account use, information generated automatically through your use of the platform, and information obtained from third-party service providers as part of our verification and payment processing workflows.

3.1 Information You Provide Directly

• Full legal name, date of birth, gender, and nationality as provided at registration.
• Email address, mobile number, and residential address in the Philippines.
• Username and encrypted password credentials for your spinco account.
• KYC identity documents: government-issued photo ID (e.g., Philippine passport, SSS ID, UMID, driver's licence), proof of address, and payment method ownership documents.
• Financial information including deposit and withdrawal transaction records, payment method details (account numbers, e-wallet references — spinco does not store full card numbers), and transaction histories.
• Communications you send to spinco including support chat transcripts, emails, and feedback submissions.
• Responsible gaming preferences including deposit limits, session limits, cooling-off requests, and self-exclusion applications.

3.2 Information Collected Automatically

• Device identifiers including IP address, device type, operating system, and browser type and version.
• Session data including login timestamps, pages visited, games played, bet amounts, session duration, and navigation paths within the platform.
• Geolocation data (country and region level) derived from your IP address for the purposes of access restriction compliance.
• Cookie data and similar tracking technologies as described in Section 7 of this Policy.

3.3 Information from Third Parties

• Identity verification results and fraud screening outputs from third-party KYC providers.
• Transaction confirmation and status data from payment processors including GCash, Maya, BPI, BDO, UnionBank, Metrobank, 7-Eleven Cliqq, Coins.ph, and USDT TRC20 channels.
• Risk and compliance data from anti-money laundering (AML) screening services where required by applicable Philippine law.

How We Use Your Personal Data

spinco uses the personal data it collects strictly for the purposes outlined below. We do not use your personal data for any purpose that is incompatible with the reasons for which it was originally collected without first obtaining your explicit consent.

Legal Basis for Processing

spinco processes your personal data on one or more of the following legal bases as recognised under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to provide the gaming services and account features you have registered to use.
• Legal Obligation: Processing is required for spinco to comply with applicable Philippine law, including KYC requirements, AML regulations, and PAGCOR regulatory obligations.
• Legitimate Interests: Processing is necessary for spinco's legitimate business interests, including fraud detection, platform security, and responsible gaming monitoring, where such interests are not overridden by your data protection rights.
• Consent: Where spinco processes your data for purposes beyond those listed above — such as direct marketing communications — we will obtain your explicit consent prior to processing. You retain the right to withdraw consent at any time.

Sharing Your Personal Data

spinco does not sell, rent, or otherwise commercially transfer your personal data to any third party. Your data may be shared with carefully selected third parties only in the circumstances described below:

• Payment Processors: Financial data necessary to process your deposits and withdrawals is shared with the relevant payment service provider (e.g., GCash, Maya, BPI, BDO, UnionBank, Metrobank, Coins.ph). These providers act as independent data controllers in respect of their own processing activities and are bound by their own privacy policies.
• KYC & Identity Verification Providers: Identity documents and personal details are shared with third-party KYC verification providers solely for the purpose of confirming your identity and eligibility as required by applicable law.
• Game Software Providers: Limited gameplay data (such as session identifiers and bet records) may be shared with licensed third-party game providers who supply the games available on the spinco platform, for the purposes of game delivery and dispute resolution.
• Regulatory & Law Enforcement Authorities: spinco may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), law enforcement agencies, or other competent Philippine authorities where required to do so by applicable law, court order, or regulatory directive. spinco will, where legally permissible, notify you of such disclosure.
• Professional Advisers: Lawyers, auditors, accountants, and other professional advisers engaged by spinco may access personal data to the extent necessary to provide their professional services, subject to confidentiality obligations.

All third parties with whom spinco shares personal data are required, by contract, to maintain the confidentiality and security of that data and to use it only for the specified purposes authorised by spinco.

Cookies & Tracking Technologies

spinco uses cookies and similar tracking technologies (such as local storage tokens and session identifiers) to operate and improve the platform. Cookies are small data files stored on your device when you visit the spinco website.

spinco uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the operation of the spinco platform. These cookies enable core functionality such as session management, login state maintenance, and security features. The platform cannot function properly without these cookies and they cannot be disabled.
• Functional Cookies: Used to remember your preferences and settings, such as language preference, display settings, and game history, to provide a more personalised experience on return visits.
• Analytical Cookies: Used to collect aggregated, anonymised data about how players interact with the spinco platform, enabling spinco to identify areas for improvement and optimise platform performance. No personally identifiable information is contained in analytical cookie data.

You can manage your cookie preferences through your browser's settings. Please note that disabling functional or analytical cookies may affect your experience on the spinco platform. Disabling strictly necessary cookies will impair your ability to use core platform features including logging in.

Data Retention

spinco retains your personal data for as long as your account remains active and for such additional period as is required by applicable Philippine law and spinco's regulatory obligations.

• Active Accounts: Personal data is retained for the full duration of your spinco account's active status.
• Post-Closure Retention: Following account closure, spinco retains personal data — including KYC documents, transaction records, and correspondence — for a minimum period of five (5) years to satisfy AML compliance requirements and potential regulatory enquiry obligations.
• Marketing Data: Where you have consented to receive marketing communications, your contact details are retained for marketing purposes until you withdraw consent. Following opt-out, your data is removed from active marketing lists promptly.
• Support Records: Customer support chat transcripts and email correspondence are retained for a period of three (3) years from the date of the interaction.

Upon expiry of the applicable retention period, spinco securely destroys or anonymises personal data in accordance with its internal data management procedures.

Data Security

spinco implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, and destruction. Our security programme includes:

• SSL/TLS encryption for all data in transit between your device and the spinco platform.
• Encryption of sensitive data at rest, including identity documents and financial records.
• Role-based access controls ensuring that spinco personnel can only access personal data to the extent necessary for their specific job function.
• Regular security audits, vulnerability assessments, and penetration testing conducted by qualified security professionals.
• Multi-factor authentication requirements for staff access to systems containing personal data.
• Incident response procedures enabling rapid detection, containment, and notification in the event of a data breach.

While spinco takes every reasonable precaution to protect your personal data, no digital transmission or storage system is completely immune to security risks. In the unlikely event of a data breach that is likely to result in a risk to your rights and freedoms, spinco will notify you and the relevant Philippine regulatory authority in accordance with its obligations under the Data Privacy Act of 2012.

Your Data Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by spinco:

1. Right to be Informed: You have the right to be informed of how your personal data is collected, used, and stored. This Privacy Policy fulfils that obligation.
2. Right to Access: You have the right to request a copy of the personal data spinco holds about you, including information on the purposes of processing, the categories of data held, and the third parties with whom it has been shared.
3. Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held by spinco. You may update basic account details directly through your account settings.
4. Right to Erasure: In certain circumstances, you have the right to request deletion of your personal data. Note that this right is subject to spinco's overriding legal obligations to retain data for regulatory compliance purposes, as described in Section 8.
5. Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to other types of processing where spinco relies on legitimate interests as its legal basis.
6. Right to Data Portability: Where technically feasible, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to request that it be transmitted to another data controller.
7. Right to Lodge a Complaint: If you believe spinco has handled your personal data in a manner inconsistent with this Policy or applicable Philippine law, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact spinco's support team via live chat or the email address provided in Section 14. spinco will respond to all data rights requests within thirty (30) days of receipt.

Children's Privacy

spinco employs age verification measures as part of its registration and KYC processes to prevent underage access. If you are a parent or guardian and have reason to believe that a minor in your care has registered an account with spinco, please contact our support team immediately so that the matter can be investigated and resolved without delay.

International Data Transfers

spinco primarily processes and stores personal data within the Philippines. In certain circumstances — for example, where spinco uses third-party technology or game software providers whose infrastructure is located outside the Philippines — your personal data may be transferred to, stored in, or processed in a jurisdiction other than the Philippines.

Where such international transfers occur, spinco takes steps to ensure that your personal data receives an equivalent level of protection to that afforded under Philippine law. This may include entering into appropriate data transfer agreements with the receiving parties or verifying that the receiving jurisdiction provides an adequate level of data protection as recognised by the National Privacy Commission.

By using the spinco platform and providing your personal data, you acknowledge and consent to the possible transfer of your data outside the Philippines in the circumstances described above, subject to the safeguards outlined in this section.

Changes to This Privacy Policy

spinco reserves the right to update or revise this Privacy Policy from time to time to reflect changes in our data processing practices, applicable legal requirements, or the features and services available on the platform.

Where changes to this Policy are material — meaning they significantly affect how we collect, use, or share your personal data — spinco will provide advance notice to registered players via email to the address associated with your account, or via a prominent notice on the spinco platform, prior to the effective date of the change.

The effective date at the top of this Policy indicates when the most recent version came into effect. We encourage you to review this Policy periodically to stay informed of how spinco is protecting your personal data. Your continued use of the spinco platform following the effective date of any revised Policy constitutes your acceptance of the updated terms.

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way spinco handles your personal data, please do not hesitate to get in touch. Our support team is available 24/7 via live chat on the spinco platform.

For formal written data privacy enquiries — including data rights requests and breach notifications — please contact us at the following address (displayed as plain text only):

spinco endeavours to acknowledge all written privacy enquiries within two (2) business days and to provide a substantive response within thirty (30) days of receipt. For complex requests, spinco may extend this period by a further thirty (30) days where reasonably necessary, subject to notifying you of the extension.

If you are not satisfied with spinco's response to your privacy enquiry, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC).

This Privacy Policy was last updated on 1 January 2026. This document supersedes all prior versions of the spinco Privacy Policy. If any provision of this Policy is found to be unenforceable under applicable Philippine law, that provision shall be modified to the minimum extent necessary to make it enforceable, and the remaining provisions shall continue in full force and effect.