Privacy Policy

1️⃣ Introduction and Scope

This Privacy Policy describes how spinh ("we," "us," or "our") collects, uses, discloses, and protects the personal information of users ("you" or "your") of the spinh Platform, including our website, mobile applications, games, and all related services.

spinh is committed to protecting your privacy and ensuring the security of your personal data in full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and all applicable PAGCOR regulations. This Privacy Policy is intended to provide transparency regarding our data practices and your rights as a data subject.

By creating an account on spinh, depositing funds, placing bets, or otherwise using our Platform, you acknowledge that you have read, understood, and consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with our data practices, please do not use the spinh Platform.

This Privacy Policy applies to all users of spinh who access our services from the Philippines or any other jurisdiction where our services are legally available. It should be read in conjunction with our Terms & Conditions, which govern your overall use of the Platform.

2️⃣ Information We Collect

spinh collects various types of personal information to provide, operate, maintain, and improve our services. The categories of personal data we collect include:

2.1 Information You Provide Directly

• Account Registration Data: Full name, date of birth, gender, email address, mobile phone number, username, password, and security questions
• Identity Verification (KYC) Data: Government-issued ID documents (e.g., Philippine passport, driver's license, UMID, SSS ID, PhilSys National ID), proof of address documents, selfie photos for identity confirmation, and any other documents required for regulatory compliance
• Financial Information: Payment method details (GCash account, Maya account, bank account numbers), transaction history, deposit and withdrawal records, and billing information
• Communications: Messages you send to our customer support team via Live Chat, email, Facebook Messenger, Viber, or phone, as well as survey responses and feedback you provide
• Marketing Preferences: Your consent preferences for receiving promotional emails, SMS messages, and push notifications

2.2 Information Collected Automatically

• Device Information: Device type, operating system, browser type and version, device identifiers (e.g., IMEI, UDID), screen resolution, and mobile carrier
• Usage Data: Pages visited, games played, bets placed, time spent on the Platform, click paths, session duration, referring URLs, and interaction patterns
• Location Data: IP address, country, city, and approximate geolocation data to ensure compliance with jurisdictional restrictions
• Cookies and Tracking Technologies: Data collected through cookies, web beacons, pixels, and similar technologies (see Section 9 for details)

2.3 Information from Third Parties

• Payment Processors: Transaction confirmation, payment status, and fraud detection information from GCash, Maya, banks, and other payment providers
• Identity Verification Services: Third-party identity verification and fraud prevention services that help us confirm your identity and comply with AML/KYC regulations
• Affiliate Partners: Referral information if you signed up through an affiliate or marketing partner

3️⃣ How We Use Your Information

spinh uses the personal information we collect for the following legitimate business purposes:

3.1 Service Provision and Account Management

• Creating and managing your spinh account
• Processing deposits, withdrawals, and other financial transactions
• Providing access to casino games, sports betting, and other gaming services
• Calculating and crediting winnings, bonuses, and promotional rewards
• Maintaining accurate account balances and transaction records

3.2 Regulatory Compliance and Legal Obligations

• Verifying your identity, age (21+), and eligibility to use our services under PAGCOR regulations
• Conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks
• Preventing fraud, money laundering, terrorist financing, and other illegal activities
• Complying with legal obligations, court orders, and requests from law enforcement or regulatory authorities
• Maintaining records as required by Philippine gaming laws and PAGCOR regulations

3.3 Platform Security and Fraud Prevention

• Detecting and preventing unauthorized access, account takeovers, and security breaches
• Monitoring for fraudulent betting patterns, bonus abuse, and collusion
• Protecting the integrity of games and ensuring fair play for all users
• Investigating and resolving disputes, violations of our Terms & Conditions, and suspected illegal activity

3.4 Customer Support

• Responding to your inquiries, complaints, and support requests via Live Chat, email, Messenger, Viber, or phone
• Troubleshooting technical issues and assisting with account problems
• Providing information about bonuses, promotions, and platform features

3.5 Marketing and Promotions (With Your Consent)

• Sending promotional emails, SMS messages, and push notifications about bonuses, new games, and special offers (only if you have opted in)
• Personalizing your experience on the Platform by recommending games and offers based on your preferences
• Conducting surveys and collecting feedback to improve our services

3.6 Analytics and Platform Improvement

• Analyzing usage patterns and player behavior to improve game selection, Platform performance, and user experience
• Conducting A/B testing and experimentation to optimize Platform features
• Developing new products, services, and features based on user feedback and data insights

4️⃣ Legal Basis for Processing

Under Philippine data protection law, spinh processes your personal data based on one or more of the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contractual obligations to you under the Terms & Conditions (e.g., providing gaming services, processing payments, managing your account)
• Legal Obligation: Processing is required to comply with Philippine laws, PAGCOR regulations, KYC/AML requirements, and other legal obligations
• Consent: You have provided explicit, informed consent for specific processing activities (e.g., receiving marketing communications, using optional features)
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security, customer support, analytics, and Platform improvement, provided these interests do not override your fundamental rights and freedoms

5️⃣ Data Sharing and Third Parties

spinh does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data with the following categories of third parties in limited circumstances:

5.1 Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including:

• Payment Processors: GCash, Maya, banks, and other payment providers that process deposits and withdrawals
• Identity Verification Services: Third-party KYC and AML compliance providers
• Cloud Hosting Providers: Secure data storage and server infrastructure providers
• Customer Support Tools: Live chat, helpdesk, and CRM software providers
• Marketing and Analytics Platforms: Email service providers, SMS gateways, analytics tools, and advertising partners (only if you have consented to marketing)

All service providers are contractually bound to handle your data securely, use it only for the purposes specified by spinh, and comply with applicable data protection laws.

5.2 Game Providers and Platform Partners

spinh partners with third-party game developers and software providers to offer a wide range of slots, live dealer games, and sports betting options. Limited user data (such as username, game session information, and betting history) may be shared with these partners solely to deliver the gaming experience.

5.3 Regulatory and Legal Authorities

We may disclose your personal information to PAGCOR, law enforcement agencies, courts, government bodies, or other authorities when required by law or when we believe in good faith that disclosure is necessary to:

• Comply with a legal obligation, court order, subpoena, or regulatory request
• Investigate potential violations of our Terms & Conditions or illegal activity
• Protect the safety, rights, or property of spinh, our users, or the public

5.4 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor, subject to the same privacy protections described in this Policy.

6️⃣ Data Retention

spinh retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements.

Specific retention periods include:

• Active Account Data: Retained for the duration of your active account and for a reasonable period thereafter to address any account-related inquiries
• KYC and Transaction Records: Retained for a minimum of five (5) years from the date of the last transaction, as required by PAGCOR regulations and Philippine AML laws
• Marketing Consent Records: Retained until you withdraw consent, plus an additional period to demonstrate compliance with marketing laws
• Security Logs and Fraud Detection Data: Retained for a reasonable period to support security audits, investigations, and legal compliance

When your account is closed (either by you or by spinh), we will retain the minimum data necessary to comply with legal obligations and may anonymize or aggregate data for statistical purposes.

7️⃣ Data Security

spinh takes the security of your personal information extremely seriously. We implement industry-standard technical, administrative, and physical security measures to protect your data against unauthorized access, disclosure, alteration, or destruction.

7.1 Technical Security Measures

• 256-bit SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using industry-standard SSL/TLS protocols
• Secure Data Storage: Personal information is stored on secure servers with restricted access, firewall protection, and encryption at rest
• Multi-Factor Authentication (MFA): Available for account login to add an extra layer of security
• Password Hashing: User passwords are hashed using cryptographic algorithms and never stored in plain text
• Regular Security Audits: Third-party penetration testing and vulnerability assessments conducted periodically

7.2 Administrative Security Measures

• Access to personal data is restricted to authorized personnel only, on a need-to-know basis
• All employees and contractors with access to personal data are bound by confidentiality obligations
• Regular staff training on data protection and security best practices
• Incident response procedures in place to detect, respond to, and mitigate security breaches

While we strive to protect your personal information, no method of transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and notifying us immediately if you suspect unauthorized access to your account.

8️⃣ Your Privacy Rights

Under the Data Privacy Act of 2012 and PAGCOR regulations, you have the following rights regarding your personal data:

8.1 Right to Access

You have the right to request access to the personal information we hold about you. We will provide you with a copy of your data in a commonly used electronic format.

8.2 Right to Rectification

If you believe any of your personal information is inaccurate, incomplete, or outdated, you have the right to request correction or update of that information. You can update most account information directly through your spinh account settings.

8.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected. However, we may retain certain information to comply with legal obligations, resolve disputes, or enforce our agreements.

8.4 Right to Object

You have the right to object to certain types of processing, including processing for direct marketing purposes. You can opt out of marketing communications at any time by clicking the unsubscribe link in emails or adjusting your preferences in your account settings.

8.5 Right to Data Portability

You have the right to request a copy of your personal data in a structured, commonly used, and machine-readable format that can be transferred to another service provider.

8.6 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.

8.7 How to Exercise Your Rights

To exercise any of these rights, please contact our Data Protection Officer at [email protected] or via our 24/7 Live Chat. We will respond to your request within thirty (30) days and may require identity verification to protect your privacy.

9️⃣ Cookies and Tracking Technologies

spinh uses cookies, web beacons, pixels, and similar tracking technologies to enhance your experience on our Platform, analyze usage patterns, and deliver personalized content and advertising.

9.1 What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They help websites remember information about your visit, such as your login status, language preferences, and browsing behavior.

9.2 Types of Cookies We Use

• Essential Cookies: Necessary for the Platform to function properly, including session management, security, and load balancing. These cookies cannot be disabled.
• Functional Cookies: Remember your preferences and settings, such as language, currency, and game filters.
• Analytics Cookies: Help us understand how users interact with the Platform, which pages are most popular, and where improvements can be made.
• Marketing Cookies: Used to deliver targeted advertising and track the effectiveness of marketing campaigns. These cookies are only set if you have consented to marketing communications.

9.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies, but doing so may affect the functionality of the spinh Platform. For more information on managing cookies, visit your browser's help section.

🔟 International Data Transfers

spinh primarily operates within the Philippines and stores data on servers located within the Philippines or in secure data centers operated by trusted cloud hosting providers. However, some of our service providers and partners may be located outside the Philippines.

When we transfer your personal data internationally, we ensure that appropriate safeguards are in place, such as:

• Standard contractual clauses approved by data protection authorities
• Ensuring the recipient country provides an adequate level of data protection
• Implementing additional security measures such as encryption and access controls

By using the spinh Platform, you acknowledge and consent to the international transfer of your personal data as described in this Privacy Policy.

1️⃣1️⃣ Children's Privacy

The spinh Platform is strictly intended for adults who are at least 21 years of age. We do not knowingly collect, use, or disclose personal information from individuals under the age of 21. Online gambling by minors is illegal under Philippine law and PAGCOR regulations.

If we become aware that we have inadvertently collected personal information from a person under 21 years of age, we will take immediate steps to delete that information and close the associated account. Parents and guardians who believe their child may have provided personal information to spinh should contact us immediately at [email protected].

🔞 You must be 21 years or older to use spinh.

1️⃣2️⃣ Changes to This Policy

spinh reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes, we will notify you by:

• Posting a prominent notice on the spinh Platform
• Sending an email notification to the address associated with your account
• Displaying an in-app notification upon your next login

Material changes will take effect seven (7) days after notification, unless a longer notice period is required by law. Your continued use of the Platform after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

The "Last Updated" date at the top of this Privacy Policy indicates when it was most recently revised.

1️⃣3️⃣ Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data protection practices, we encourage you to contact us. Our Data Protection Officer and customer support team are here to help.

Data Protection Officer

Email: [email protected]

Customer Support

24/7 Live Chat: Available on the spinh Platform

Email: [email protected]

Support Channels: Live Chat, Facebook Messenger, Viber, Email

We aim to respond to all privacy-related inquiries within thirty (30) days. For urgent security concerns, please contact us immediately via Live Chat.