spinoo Privacy Policy

01 Who We Are

This Privacy Policy is issued by spinoo ("spinoo", "we", "us", "our"), the operator of the online casino and sports betting platform accessible at https://spinoo.app (the "Platform"). spinoo is committed to protecting the privacy and personal data of all individuals who interact with the Platform, whether as registered players, visitors, or prospective users.

spinoo operates primarily for players based in the Philippines and processes personal data in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations (IRR), as enforced by the National Privacy Commission (NPC) of the Philippines.

02 Personal Data We Collect

spinoo collects only the personal data necessary to operate your account and deliver our services. The categories of personal data we may collect are set out below:

spinoo does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, health records, or sexual orientation. If any such data is inadvertently received, it will be deleted promptly.

03 How We Collect Your Data

3.1 Directly From You

The majority of personal data spinoo holds is provided directly by you when you register an account, complete identity verification, make deposits or withdrawals, contact our support team, or respond to surveys and promotional communications.

3.2 Automatically

When you visit the spinoo Platform, we automatically collect certain technical and usage data through cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, browser information, device identifiers, and behavioural data such as which games you play and how long your sessions last.

3.3 From Third Parties

spinoo may receive personal data about you from third-party service providers in the following circumstances:

• From payment processors (such as GCash, PayMaya, or card networks) to confirm the status and authenticity of your transactions.
• From identity verification and KYC service providers used to confirm your identity and screen against sanction lists.
• From fraud prevention and anti-money laundering (AML) screening services to fulfil our regulatory obligations.
• From analytics providers that help spinoo understand aggregate Platform usage patterns.

04 Why We Use Your Personal Data

spinoo uses your personal data for the following specific purposes. We do not use your data in ways that are incompatible with these stated purposes without first obtaining your consent or establishing a new lawful basis.

• Account creation and management: To register your account, verify your identity, and maintain the security of your spinoo account throughout your use of the Platform.
• Transaction processing: To process your deposits and withdrawals accurately and efficiently via your chosen payment method, whether GCash, PayMaya, BPI, BDO, Metrobank, Visa, or Mastercard.
• Regulatory compliance: To fulfil spinoo's obligations under Philippine gaming regulations, anti-money laundering laws, and the Data Privacy Act of 2012, including the maintenance of transaction records and player activity logs.
• Fraud prevention and security: To detect, prevent, and investigate fraudulent activity, multi-accounting, bonus abuse, and other prohibited conduct that may harm other players or spinoo's platform integrity.
• Responsible gaming: To monitor your gaming activity and identify patterns that may indicate problem gambling behaviour, enabling spinoo to fulfil its responsible gaming obligations and offer appropriate support tools.
• Customer support: To respond to your enquiries, resolve disputes, and assist with technical issues related to your spinoo account or the Platform.
• Service improvement: To analyse aggregate usage patterns, conduct research, test new features, and improve the overall quality and user experience of the spinoo Platform for Filipino players.
• Marketing communications: To send you information about spinoo promotions, bonuses, and new games where you have provided consent or where we have a legitimate interest to do so. You may withdraw your marketing preferences at any time.

05 Legal Basis for Processing

spinoo processes your personal data under one or more of the following lawful bases, as established under the Data Privacy Act of 2012 (RA 10173) and its IRR:

• Contractual necessity: Processing is necessary to perform the contract between spinoo and you as a registered player — including account management, game access, and payment processing.
• Legal obligation: Processing is required to comply with applicable Philippine laws, including gaming regulations, AML requirements, and tax reporting obligations.
• Legitimate interests: Processing is necessary for spinoo's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement — provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and non-essential cookies, spinoo relies on your explicit, freely given consent. You may withdraw this consent at any time without affecting any prior processing.

06 Sharing Your Personal Data

spinoo does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only where strictly necessary and under appropriate data protection agreements:

6.1 Service Providers

spinoo engages trusted third-party service providers to assist in operating the Platform, including payment processors, KYC and identity verification providers, cloud hosting providers, customer support software vendors, and analytics platforms. These providers are contractually bound to process your data solely on spinoo's instructions and in accordance with applicable data protection law.

6.2 Regulatory and Legal Authorities

spinoo may be required to disclose your personal data to Philippine gaming regulators, law enforcement agencies, the National Privacy Commission, financial intelligence units, or courts of law where required or permitted by applicable law. spinoo will disclose only the minimum data necessary to satisfy such requirements.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of spinoo's business, your personal data may be transferred to the successor entity. You will be notified of any such transfer and any material changes to how your data is processed as a result.

6.4 With Your Consent

spinoo may share your data with other third parties where you have given your explicit, informed consent for a specific sharing purpose.

07 Cookies & Tracking Technologies

spinoo uses cookies and similar technologies on the Platform to ensure it functions correctly, to remember your preferences, and to help us understand how players use the Platform so we can improve it. The categories of cookies spinoo uses are as follows:

• Strictly necessary cookies: Essential for the operation of the Platform, including maintaining your login session and enabling secure navigation. These cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and display options, so you do not need to re-enter them on each visit.
• Analytical cookies: Used to collect aggregate, anonymised information about how players interact with the Platform — such as which pages are visited most frequently. This helps spinoo identify areas for improvement.
• Marketing cookies: Used, with your consent, to deliver relevant promotional content about spinoo games and offers. You may withdraw consent for marketing cookies at any time through the cookie preferences settings.

You can manage your cookie preferences at any time through your browser settings or the spinoo cookie consent panel. Please note that disabling strictly necessary cookies may affect the functionality of the Platform.

08 Data Retention

spinoo retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying legal, accounting, and regulatory requirements. The general retention periods applied by spinoo are as follows:

• Account and identity data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, as required by Philippine gaming and AML regulations.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, in accordance with applicable financial record-keeping obligations.
• Support and communication data: Retained for three (3) years from the date of the most recent communication, unless a longer period is required to resolve an ongoing dispute or comply with a legal obligation.
• Technical and usage data: Typically retained for thirteen (13) months from the date of collection, after which it is aggregated and anonymised.
• Marketing consent records: Retained for as long as you remain a registered player or until you withdraw your consent, whichever comes first.

When personal data is no longer required, spinoo securely deletes or irreversibly anonymises it so that it can no longer be linked to an identifiable individual.

09 Data Security

spinoo implements a comprehensive set of technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the spinoo Platform.
• Encryption of sensitive data at rest, including financial records and identity verification documents.
• Strict access controls ensuring that only authorised spinoo personnel with a legitimate need can access personal data.
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure.
• Two-factor authentication (2FA) requirements for internal systems access and, optionally, for player accounts.
• Comprehensive employee training on data protection obligations and security best practices.

While spinoo takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are also responsible for keeping your account credentials confidential and for notifying spinoo promptly of any suspected unauthorised account access.

10 Your Data Protection Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by spinoo. You may exercise any of these rights by contacting our Data Protection Officer:

• Right to Access: You may request a copy of the personal data spinoo holds about you, along with information about how it is being processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data spinoo holds about you.
• Right to Erasure: You may 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.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time, and to other processing based on legitimate interests where you have grounds relating to your particular situation.
• Right to Block or Restrict Processing: You may request that spinoo restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data.
• Right to Data Portability: You may request that spinoo provide your personal data in a structured, commonly used, machine-readable format so that it can be transferred to another service provider.
• Right to Complain: If you believe spinoo has violated your data privacy rights, you may lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).

spinoo will respond to all data subject rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with prior notification to you.

11 Children & Minors

The spinoo Platform is strictly intended for individuals who are 21 years of age or older, consistent with Philippine law governing online gambling. spinoo does not knowingly collect personal data from individuals under the age of 21.

If spinoo becomes aware that personal data has been collected from a person under 21 years of age, that data will be deleted immediately and the associated account will be closed. Any deposits made by underage individuals will be refunded to the original payment method where technically possible, after deducting any costs associated with the closure.

If you have reason to believe that a minor is using the spinoo Platform or has submitted personal data to spinoo, please notify our support team immediately via live chat or at [email protected] so that the matter can be investigated and resolved promptly.

12 International Data Transfers

spinoo's primary infrastructure and data storage is located in the Asia-Pacific region, with the Philippines as the primary jurisdiction of operations. In some cases, personal data may be processed by third-party service providers located outside the Philippines — for example, cloud infrastructure providers or international payment processors.

Where personal data is transferred outside the Philippines, spinoo ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. Such safeguards may include standard contractual clauses, binding corporate rules, or transfers to jurisdictions that the NPC has recognised as providing adequate levels of data protection.

You may request details of the safeguards spinoo relies upon for international data transfers by contacting our Data Protection Officer.

13 Changes to This Privacy Policy

spinoo reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or business operations. The "Effective Date" at the top of this document will always reflect when the current version came into force.

Where changes are material — meaning they significantly affect how we process your personal data or your rights under this policy — spinoo will provide at least fourteen (14) days' advance notice via your registered email address or a prominent notice on the Platform before the changes take effect.

Your continued use of the spinoo Platform after the effective date of any amended Privacy Policy constitutes your acknowledgement and acceptance of the updated terms. If you do not agree with any changes, you may close your account in accordance with the account closure process described in the spinoo Terms & Conditions.

Previous versions of this Privacy Policy are available on request by contacting the spinoo Data Protection Officer.

14 Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by spinoo, you may contact our Data Protection Officer (DPO) through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the spinoo Platform. Average response time under 2 minutes.
• Support Email: [email protected] (plain text — not a clickable link)
• Response Time: All privacy-related enquiries will be acknowledged within 48 hours and resolved within 30 calendar days.
• Regulatory Authority: If you are not satisfied with spinoo's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.
• Service Region: Players across Manila, Cebu, Davao, Quezon City, Makati, and all regions of the Philippines.

This Privacy Policy was last reviewed and updated on 1 January 2026. For the version history or previous editions, please contact the spinoo support team.