spintime Privacy Policy

This Privacy Policy is issued by spintime ("spintime," "we," "us," or "our"), the operator of the online casino platform accessible at spintime.one. spintime is the data controller responsible for the personal data of players and visitors collected through the Platform.

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or need to report a data privacy concern, please contact the spintime Data Privacy Officer:

This Privacy Policy applies to all personal data collected by spintime in connection with your use of the spintime Platform, including the website at spintime.one, any associated mobile applications, and all games, features, promotions, and services offered through the Platform.

This Policy applies to registered players, prospective players who visit the Platform without registering, and any other individuals whose personal data spintime processes in connection with the Platform's operation.

This Privacy Policy is governed by and construed in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and the implementing rules and regulations issued by the National Privacy Commission ("NPC"). spintime is committed to full compliance with the DPA and all applicable NPC issuances.

spintime collects personal data from you directly when you register an account, make a deposit or withdrawal, contact support, or interact with the Platform. We also collect certain data automatically when you visit the Platform. The categories of personal data we collect are set out in the table below.

spintime uses your personal data only for the purposes described in this Privacy Policy. The primary purposes for which we process your personal data are:

• Account registration and management: To create and maintain your spintime player account, verify your identity and age (21+), and manage your account settings and preferences.
• Payment processing: To process deposits and withdrawals via GCash, Maya, Philippine bank transfer, and debit card, and to maintain accurate financial records.
• Regulatory compliance: To comply with PAGCOR licensing requirements, anti-money laundering (AML) obligations, and other applicable Philippine laws and regulations, including the DPA.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Responsible gaming: To monitor gameplay patterns for signs of problem gambling and to administer self-exclusion and other player protection tools.
• Platform improvement: To analyse usage patterns and improve the functionality, performance, and content of the spintime Platform.
• Marketing communications: To send you promotional offers, bonus notifications, and news about spintime, where you have consented to receive such communications. You may opt out at any time.

Under the Data Privacy Act of 2012, spintime processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and spintime — including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with PAGCOR regulations, AML laws, tax obligations, and other applicable Philippine legal requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and analytics, where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

spintime does not sell, rent, or trade your personal data to third parties. We share your personal data only in the following limited circumstances:

• Payment processors: GCash, Maya, and Philippine banking partners, to the extent necessary to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML service providers engaged to assist with age and identity verification.
• Game software providers: Licensed game studios and platform providers whose games are available on spintime, to the extent necessary to deliver game services and maintain game integrity.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine authorities, where required by law or regulatory obligation.
• Law enforcement: Philippine law enforcement agencies, where required by a valid legal order or where disclosure is necessary to prevent or investigate criminal activity.
• Professional advisers: Lawyers, auditors, and accountants engaged by spintime, subject to professional confidentiality obligations.

spintime retains your personal data for as long as your spintime account is active and for such additional period as is required by applicable law or regulatory obligation. The key retention periods applicable to spintime player data are:

Upon expiry of the applicable retention period, spintime will securely delete or anonymise your personal data in accordance with its data disposal procedures.

spintime uses cookies and similar tracking technologies on the Platform. Cookies are small text files stored on your device that help the Platform function correctly and allow spintime to understand how players use the Platform.

Types of Cookies Used

• Essential cookies: Required for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled without affecting Platform functionality.
• Functional cookies: Remember your preferences such as language settings and game display options.
• Analytics cookies: Collect anonymised data about how players use the Platform, which pages are visited most frequently, and where errors occur. This data helps spintime improve the Platform.
• Marketing cookies: Used to deliver relevant promotional content to you on the Platform, based on your activity. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may prevent you from accessing certain features of the spintime Platform.

spintime implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the spintime Platform
• Encryption of sensitive data at rest, including financial data and identity documents
• Role-based access controls limiting access to personal data to authorised personnel only
• Regular security assessments and penetration testing of the Platform
• Staff training on data protection obligations and information security practices
• Incident response procedures for detecting, reporting, and managing personal data breaches

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

• Right to be informed: The right to be informed of how your personal data is collected, used, and shared — which this Privacy Policy fulfils.
• Right of access: The right to request a copy of the personal data spintime 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 spintime'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 and to transmit it to another controller, where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission if you believe your data protection rights have been violated.

To exercise any of these rights, please contact the spintime Data Privacy Officer at the contact details provided in Section 1. spintime will respond to all data subject requests within 15 business days of receipt, in accordance with NPC guidelines.

The spintime Platform is strictly intended for adults aged 21 years and above. spintime does not knowingly collect personal data from individuals under the age of 21. If spintime 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 are a parent or guardian and believe that your child has provided personal data to spintime, please contact the spintime Data Privacy Officer immediately so that appropriate action can be taken.

spintime reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Where changes are material, spintime will notify registered players via email or an in-platform notification prior to the changes taking effect.

The effective date of the current version of this Privacy Policy is stated at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how spintime protects your personal data. Your continued use of the Platform following the effective date of any update constitutes your acknowledgement of the updated Privacy Policy.

If you have a concern about how spintime handles your personal data, we encourage you to contact the spintime Data Privacy Officer in the first instance. spintime takes all privacy complaints seriously and will investigate and respond to your concern promptly.

If you are not satisfied with spintime's response, or if you believe that spintime has violated your rights under the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. The NPC is the independent regulatory body responsible for enforcing the DPA in the Philippines.