spinoo Privacy Policy

spinoo is deeply committed to protecting the privacy and personal data of every player who uses our platform. As a PAGCOR-licensed online casino operating in the Philippines, we are legally obligated — both under our licensing conditions and under Philippine law — to handle your personal data with care, transparency, and proportionality.

This Privacy Policy sets out, in plain terms, how spinoo collects, uses, stores, shares, and ultimately deletes your personal information. We have written this document to be as clear as possible, not to bury important disclosures in legal language that nobody reads. We want you, as a spinoo player, to understand exactly what happens with your data from the moment you visit spinoo.cam to the moment your account is permanently closed.

If you have any questions about how spinoo handles your personal data that are not addressed in this Policy, our dedicated privacy support contact is available to assist you. Details are provided in Section 13 of this Policy.

By creating a spinoo account or continuing to use our platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. This consent is provided voluntarily and may be withdrawn at any time, subject to the limitations described in Section 10 of this Policy.

spinoo collects the minimum personal data necessary to deliver a safe, compliant, and functional gaming experience. The categories of personal data we collect are as follows:

spinoo does not knowingly collect special categories of sensitive personal data — such as health information, political opinions, religious beliefs, or racial or ethnic origin — unless you voluntarily provide such information in the course of a support interaction, in which case it will be treated with heightened protection and used only for the specific purpose for which it was shared.

spinoo collects personal data through the following means:

Direct Collection

The majority of your personal data is collected directly from you when you: register a spinoo account and complete the onboarding form; submit KYC (Know Your Customer) verification documents; make a deposit or request a withdrawal; contact spinoo customer support; participate in a survey or promotional campaign; or update your account profile settings.

Automated Collection

When you access spinoo.cam or the spinoo mobile application, our systems automatically collect certain technical data, including your IP address, device fingerprint, browser type and version, operating system, and session activity logs. This data is collected through standard server logs, session cookies, and analytics tools. For more information about cookies specifically, please refer to Section 9 of this Policy.

Third-Party Sources

spinoo may receive personal data about you from third-party sources in limited circumstances, including: payment processors and e-wallet providers (GCash, Maya) who confirm transaction status and account ownership for fraud prevention purposes; identity verification service providers used to validate government ID documents during KYC; and fraud prevention databases maintained by PAGCOR or other recognized Philippine regulatory bodies.

In all cases where data is received from third parties, spinoo ensures that such data was collected and transferred in accordance with applicable law and that its use by spinoo is limited to the specific purpose for which it was obtained.

spinoo processes your personal data only for specific, legitimate purposes. We do not process personal data in ways that are incompatible with the purposes declared at the time of collection. The primary purposes for which spinoo processes your data are:

• Account creation and management: To register your spinoo account, verify your identity, and maintain your account in accordance with our Terms and Conditions;
• Service delivery: To provide access to games, process bets, calculate winnings, and deliver all features of the spinoo platform;
• Payment processing: To process deposits and withdrawals through GCash, Maya, BPI, BDO, UnionBank, Metrobank, and other accepted payment channels;
• Regulatory compliance: To comply with PAGCOR licensing requirements, Philippine anti-money laundering laws (AMLA), and the Data Privacy Act of 2012;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, account compromise, money laundering, and other illegal conduct on the spinoo platform;
• Customer support: To respond to your inquiries, resolve complaints, and provide technical assistance;
• Responsible gaming: To monitor gaming patterns, enforce deposit limits and self-exclusion requests, and identify players who may need responsible gaming support;
• Marketing communications: To send you promotional offers, bonus notifications, and spinoo news where you have consented to receive such communications, or where permitted by applicable law on the basis of our existing customer relationship;
• Platform improvement: To analyze aggregated usage data to improve spinoo's games, features, performance, and user experience.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, spinoo processes your personal data on the following legal grounds:

• Contractual necessity: Processing is necessary to perform the contract between you and spinoo (your account registration and our Terms and Conditions), including delivering gaming services and processing financial transactions;
• Legal obligation: Processing is required to comply with PAGCOR licensing conditions, Philippine AMLA obligations, PAGCOR Responsible Gaming Framework requirements, and other applicable Philippine laws;
• Legitimate interests: Processing is necessary for spinoo's legitimate interests in fraud prevention, platform security, and product improvement, provided such interests are not overridden by your privacy rights and freedoms;
• Consent: For marketing communications and non-essential cookies, spinoo relies on your explicit consent, which you may withdraw at any time without affecting the lawfulness of processing that occurred prior to withdrawal.

spinoo does not sell your personal data to third parties. We do not share your personal data with third parties for their own independent marketing purposes. Your data is shared only in the following limited and controlled circumstances:

Service Providers (Data Processors)

spinoo engages trusted third-party service providers to assist in delivering our services. These include payment processors (GCash/Maya/banks), KYC identity verification platforms, game software providers (JILI, Pragmatic Play, PG Soft), cloud hosting providers, and customer support platforms. All such service providers are contractually bound to process your data only on spinoo's instructions and to maintain appropriate security standards.

Regulatory and Legal Disclosure

spinoo may be required to disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), law enforcement agencies, or courts of competent jurisdiction where required by applicable Philippine law or by a valid legal process. In such cases, spinoo will disclose only the minimum data necessary to satisfy the legal requirement and will notify you of such disclosure where permitted by law.

spinoo retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active account data: Retained for the duration of your active spinoo account plus a minimum of five (5) years following account closure, in accordance with PAGCOR licensing requirements and AMLA record-keeping obligations;
• Transaction records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, consistent with Philippine AMLA requirements;
• KYC documentation: Identity verification documents are retained for five (5) years from account closure or the last verified transaction, whichever is later;
• Support communications: Records of customer support interactions are retained for three (3) years from the date of the last communication;
• Marketing consent records: Records of your marketing preferences and consent/withdrawal history are retained for three (3) years from the date of the most recent preference change;
• Technical logs: Server logs and session data are retained for ninety (90) days for security monitoring purposes, after which they are anonymized or deleted.

Upon expiry of applicable retention periods, spinoo securely destroys or anonymizes personal data in a manner that prevents reconstruction or identification of the data subject.

spinoo implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security framework includes the following controls:

• Encryption in transit: All data transmitted between your device and spinoo's servers is protected using TLS 1.2 or higher encryption (SSL/HTTPS), ensuring that your personal data and financial transactions cannot be intercepted in transit;
• Encryption at rest: Sensitive data stored in spinoo's databases — including passwords (stored as salted cryptographic hashes), financial account details, and identity documents — is encrypted at rest using AES-256 or equivalent standards;
• Access controls: Access to personal data within spinoo's internal systems is restricted on a strict need-to-know basis, with role-based access controls, multi-factor authentication for staff systems, and detailed access audit logs;
• Regular security assessments: spinoo conducts periodic penetration testing, vulnerability assessments, and security audits, both internally and through third-party security firms;
• Incident response: spinoo maintains a documented data breach response plan. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, spinoo will notify the National Privacy Commission (NPC) and affected data subjects in accordance with the Data Privacy Act of 2012 and NPC Circular No. 16-03.

spinoo uses cookies and similar tracking technologies on the spinoo.cam website and mobile applications to improve your experience, maintain your session, and analyze how players use our platform. A cookie is a small text file placed on your device when you visit a website.

Types of Cookies We Use

• Strictly necessary cookies: Required for the spinoo platform to function correctly. These include session authentication cookies that keep you logged in during a gaming session. These cookies cannot be disabled without preventing you from using the platform;
• Functional cookies: Remember your preferences, such as your preferred language, display settings, and whether you have dismissed certain notifications;
• Analytics cookies: Collect anonymized information about how spinoo players navigate our platform, which pages are most visited, and where players encounter difficulties. This data helps us improve the spinoo experience for all Filipino players;
• Marketing cookies: Used only where you have provided explicit consent, to deliver spinoo promotional content relevant to your gaming preferences.

You can manage cookie preferences through your browser settings or, for non-essential cookies, through the cookie preference center accessible on spinoo.cam. Please note that disabling cookies beyond strictly necessary ones may affect certain features of the spinoo platform.

Under the Data Privacy Act of 2012, you hold the following rights with respect to the personal data spinoo processes about you. You may exercise any of these rights by contacting spinoo's data privacy support team at the contact details provided in Section 13.

• Right to be informed: You have the right to be notified of how spinoo collects and uses your personal data — this Privacy Policy fulfills that obligation;
• Right of access: You have the right to request a copy of the personal data spinoo holds about you, including information about how it is being processed;
• Right to rectification: You have the right to request correction of inaccurate or incomplete personal data spinoo holds about you. Basic profile information can be updated directly in your spinoo account settings;
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to spinoo's legal retention obligations under PAGCOR licensing and AMLA requirements;
• Right to object: You have the right to object to spinoo's processing of your personal data where such processing is based on legitimate interests, including the right to opt out of direct marketing communications at any time;
• Right to data portability: You have the right to receive a copy of the personal data you have provided to spinoo in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint: If you believe spinoo has violated your data privacy rights, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.

spinoo will respond to all verifiable data rights requests within fifteen (15) business days. In complex cases, this period may be extended by an additional fifteen (15) business days, with notification provided to you of the extension and its reason.

spinoo's platform and services are strictly intended for adults aged 21 years and above, in compliance with PAGCOR regulations. spinoo does not knowingly collect, use, or retain personal data from individuals under the age of 21.

During the account registration and KYC verification process, spinoo requires documentary proof that the registrant meets the minimum age requirement. Any account found to have been created by or on behalf of a person under 21 years of age will be immediately suspended, and any personal data collected in connection with that account will be securely deleted, except where retention is required to document the violation for regulatory compliance purposes.

spinoo may update this Privacy Policy periodically to reflect changes in our data practices, applicable Philippine law, PAGCOR regulatory requirements, or technological developments. When we make material changes — those that meaningfully affect how your data is collected, used, or your privacy rights — we will provide advance notice through one or more of the following channels: a prominent notice on the spinoo.cam homepage, an email notification to your registered email address, or an in-app notification displayed upon your next login to the spinoo platform.

Material updates will be effective no fewer than seven (7) calendar days from the date of notification, except where earlier implementation is required by law or regulatory directive. Non-material changes — such as grammatical corrections, clarifications that do not alter the substance of our data practices, or updates to contact information — may take effect immediately upon publication.

The "Last Updated" date at the top of this Privacy Policy will always reflect the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how spinoo protects your data. Continued use of the spinoo platform following the effective date of any update constitutes your acceptance of the revised Policy.

spinoo has designated a Data Privacy Officer (DPO) in accordance with Section 21 of the Data Privacy Act of 2012 and NPC Circular No. 17-01. The DPO is responsible for overseeing spinoo's compliance with data privacy obligations and serving as the primary point of contact for data subjects exercising their rights under the Data Privacy Act.

For complaints that cannot be resolved directly with spinoo, Filipino players may contact the National Privacy Commission (NPC) through its official channels. spinoo cooperates fully with all NPC investigations and will provide requested information in a timely manner in response to valid NPC orders or inquiries.