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SpinEmpire/Privacy Policy

Privacy Policy

General provisions

  • As a Data Controller and according to the rules of gambling, we have a legal obligation to process player's personal data so that they can participate in games and use optional services. This Privacy Policy explains what and why we collect and use players' personal data.

    Spinempire.com is operated by GBL Solutions N.V., a company registered and established under the laws of Curacao. GBL Solutions N.V. is regulated by the GCB (Curaçao Gaming Control Board) - OGL/2024/589/0556. GBL Solutions N.V.’s registration number is 155090 and its registered address is Seru Loraweg 17, Curaçao. Ramtinar Techconsult Limited is a subsidiary of GBL Solutions N.V., acting as a Payment Agent on behalf of GBL Solutions N.V., registered in Cyprus with registered address Kasou 18, Office 41, 1086, Nicosia, Cyprus and registration number ΗΕ 412602.

    This website owned and operated by a company registered in the Republic of Cyprus, with its principal place of business at Nicosia, Cyprus. All gambling services are provided by parent company, with its registered address at Curacao. The website is operated under eGaming License, issued Authorized and Regulated by the Government of Curacao.

    By registering on the site, you accept this Privacy Policy. Please do not use this Website if you don’t accept the terms and conditions of the Privacy Policy and don’t wish to provide us with required personal data.

    Please note that the Privacy Policy is an agreement between you and the company. We may make changes to this Policy from time to time. We recommend that you regularly check for any changes to this Privacy Policy. Your continued use of or access to the website and/or its services following the posting of any changes constitutes acceptance of the Privacy policy.

Data Collection

The personal data we collect for use and processing must include, without limitation:

  • 1

    Personal Data You Provide Directly
    Depending on the way you access, use, or interact with our services, we collect the following personal data directly from you:
    • Registration Data: When you create an account on our website, you are required to provide personal data, which includes your email address, date of birth, country of residence, phone number, gender, full name, social security number, zip code, and username. During the registration process, we may also automatically collect your IP address and location data. This also refers to any other data you send later via the Website or by e-mail (e.g. first and last name, date of birth, email address, phone number).
    • Communication and Feedback Data: messages, correspondence, requests, support chats, emails and other communications exchanged between you and us through the Website, email, chat or other communication channels, as well as your participation in surveys, feedback forms or other customer evaluations that we may conduct from time to time. The Casino reserves the right to retain copies of any communications that user sends to us (including copies of any emails) in order to be able to maintain accurate records of the user acting on the Website.
    • Due Diligence Data: We may collect your identity card number, driving licence number, passport number, proof of address, social security number, source of wealth or source of funds information, Bank ID, and financial statements or other financial details. This information is collected to comply with our due diligence and KYC obligations, to verify your age and identity, to meet anti-money laundering (AML) requirements, and to comply with our licence conditions or other applicable legal requirements.
    • Financial Information: We may collect financial information, including Bank ID, CPR number, CPF number, IBAN, and payment system details, in order to process deposits and withdrawals to and from your account. This information may also be used for KYC and AML compliance purposes.

  • 2

    Personal Data We Collect Automatically
    • Device Information: We may receive information about the device, browser, and software you use to access our services, including your Internet Protocol (IP) address, operating system version, and device identifiers.
    • Logs and Usage Information: To understand how you use our services and to improve their functionality, we may automatically collect information about your interactions with our services. Our servers may log usage data when you interact with our website, including records of your activity, such as viewing content, clicking advertisements, performing searches, sharing our services on social media, the date and time of your sessions, the pages you visit and the time spent during a session. Some of this information may be collected through cookies and similar technologies.
    • Location Information: We may collect or infer general location information when you use our services.

  • 3

    Personal Data We Receive From Third Parties
    We may receive personal data about you from other sources in order to provide and personalize our services and/or comply with our legal obligations. Such sources may include:
    • Publicly available sources, including public and government databases, the internet, social media platforms, online media, and other publicly accessible sources.
    • Commercially available databases and third-party entities, including financial institutions, credit institutions, fraud prevention agencies, and public authorities. These sources may assist us in verifying your information and investigating suspicious activities, particularly for fraud prevention and AML purposes.
    • Personal data you have made public, including information available on social media platforms, linked accounts such as Facebook or Google, and other publicly accessible digital platforms.

Data Processing

    We must process your personal data in order to provide our services, in particular for the following purposes:

  • 1

    Processing of your bets and transactions, including the use of credit cards and online payment systems;

  • 2

    Providing you with the gaming and other services you wish to receive on our Website;

  • 3

    Providing customer support, for example configuration and management of your account;

  • 4

    Identifying and performing the necessary verification checks;

  • 5

    Providing members with promotional information or advertising content from some of our business partners associates and affiliates;

  • 6

    Fulfillment of legal obligations, including compliance with laws on combating money laundering and the financing of terrorism;

  • 7

    Monitoring and investigating transactions to prevent fraud, willful delays, money laundering and other illegal or abnormal gambling activities;

  • 8

    Analysis of market trends and customer needs (participation in surveys is optional, and you can always refuse to participate);

  • 9

    Research and statistical analysis of summary data.

Lawful Basis for Data Processing

  • The Casino processes your personal data in accordance with applicable data protection laws and regulations, including General Data Protection Regulation (GDPR), the National Ordinance on Games of Chance (LOK), and related legislation.
    We process Personal Data only where we have a lawful basis under applicable data protection laws, including where processing is necessary to perform our contract with you, comply with legal obligations, pursue our or a third party’s legitimate interests, obtain and rely on your consent, establish, exercise or defend legal claims, or rely on any other lawful basis available under applicable law.

Contact Details

  • For questions about this Privacy Policy, general information requests or requests to exercise your privacy rights, you may contact us using the contact details made available on the Website.
    Customer support: [email protected].
    Subject line: “Privacy Request” or “Information Request”.
    Your request will be forwarded to the responsible department and reviewed within the statutory timeframes.

Marketing

  • We may use your personal data, such as your email and phone number, to send you advertising messages about our products, services and promotions, including those of our business partners, software providers etc.
    If you no longer wish to receive advertising messages, you can unsubscribe by contacting customer service [email protected].
    In addition, please note that by accepting a prize through participation in a contest, you agree that we can use your name and/or nickname for advertising purposes without additional compensation, except when prohibited by law.

Personal Data Receipt

  • We won’t collect your personal data without your knowledge. However, we may automatically collect some of your data if you have provided it by using our services and interacting with us.
    We may also legally receive some of your data from online sellers and service providers such as fraud prevention companies. In addition, we may use third party services and technical support to process your online transactions and original game content.
    Please be assured that your Personal data is treated securely and in accordance with the Privacy policy. All of your data will only be disclosed outside the Company to third parties in accordance with the Privacy policy, and we will take all steps necessary to ensure that our agreements with third party service providers always protect your personal data.

Data Transfer To Third Parties

  • 1

    We do not sell or rent your personal data to third parties. We may disclose your personal data if required by law, a court order or other legal requirement or warrant.

  • 2

    We may also disclose your personal data to a supervisory or a law enforcement agency if we consider it necessary to protect the legitimate interests of the Company, its customers or any third party.

  • 3

    Personal data will only be disclosed to third parties in the following cases:

    1. - If required by law;

    2. - If the Website must exchange data with its payment system operators in order to simplify payment transactions in accordance with their privacy policy (in particular, most credit card transactions are processed by Wirecard Bank AG, whose privacy policy applies to these transactions);

    3. - To fulfill our legal and regulatory obligations towards licensing and official authorities, as well as all obligations arising from any other applicable law and towards any other regulatory authority in other jurisdictions;

    4. - If the Company considers the disclosure necessary to protect itself or the player or third parties, to investigate fraud or to respond to a government request;

    5. - If our marketing service providers require such data to conduct their business;

    6. - To any other third party with the player's prior consent.

  • 4

    We use third-party services to process certain personal data.
    Our service providers support the Website, in particular with regard to hosting and management, marketing, analytics, modernization and email newsletters. We guarantee that the transfer of personal data to a recipient is carried out in accordance with the applicable data protection law and that a data controller is subject to the same obligations as us under a relevant service agreement.

  • 5

    Our websites may also include social networking features (for example, share or like buttons). These features are provided by third-party social media platforms such as Facebook and therefore data processing is subject to the respective social media privacy policy.

  • 6

    In addition, we may disclose personal data if we acquire new businesses. In the event of changes in the structure of the Company, such as a merger or a total or partial acquisition by another company, it is very likely that our customers' personal data will be included in the contract of sale or transfer. As part of our Privacy policy, we will notify our players by email before making such a transfer of personal data.

  • 7

    Please note that our website may contain hyperlinks to websites operated by third parties. We are not responsible for any privacy policy and data processing of any external website other than those established by us.

Transfer Of Data Outside EU/EEA

  • We may process your personal data in countries outside of the EU/EEA. When we transfer your personal data to our affiliates or third parties, we make sure that appropriate safeguards have been put in place before such transfer to ensure your personal data is afforded a high standard of protection. This includes transferring personal data only to countries recognized by the European Commission as providing adequate protection, employing Standard Contractual Clauses approved by the European Commission, or implementing other legally recognized safeguards.

Data Retention

  • You and the Casino have the right to delete your account at any time according to our Terms and Conditions. After your account is deleted, we must keep your personal data on paper for the period required by law. This data should only be used if the competent authorities request for assistance in financial or tax, fraud, money laundering investigations or any other criminal investigations.

    Please note that due to AML rules established in licensing jurisdictions of the European Union, we are required to retain the personal data of players for as long as the player has an account and for at least five years since the player's last transaction or the closure of the account. Therefore, data erasure requests will not be processed before this period.

Security of Personal Data

  • According to law, we must comply with data protection requirements in the way in which we use any personal information collected from You in Your use of the Services. We therefore take very seriously our obligations in relation to the way in which we use Your personal information.
    As stated under our Terms and Conditions both, you and the Casino can decide to have your Player Account closed at any time. Following closure of your account, we will retain your personal data on record for as long as required by law. This data shall only be used should it be required by competent authorities in cases of enquiries regarding financial and fiscal records, fraud, money laundering or investigations into any other illegal activity.

    You are to note that due to AML regulations in licensed gaming jurisdictions in the European Union, we are obliged to retain personal data of players submitted during registration and any data passed on during the operative period of a Player Account for a minimum of five years from last player transaction or account closure. Therefore, requests for erasure prior to the lapse of this period cannot be entertained.
    We hereby acknowledge that we are required to strictly comply with data protection standards during its collection and processing for the purposes of managing your account. Therefore, we strive to protect your personal data and respect your privacy in accordance with best practices and applicable standards. We will take all reasonable precautions to ensure that all of your data is safe and secure.

Use Of Cookies

  • When you visit the Website, our system automatically collects your data, such as your browser, IP address and referring website.
    This collection may be carried out in collaboration with our platform suppliers and partners. They can provide us with demographics and interests data of our visitors. We do not use collected data to identify you personally without your prior consent. We use cookies and similar tracking tools to collect required data.
    Cookies are small text files that are placed on your computer or mobile device when you browse our pages.
    Certain cookies are necessary for the Website to work; others improve your web surfing experience and help us provide excellent customer service.
    Below are the types of cookies we use and their purposes.
    Required cookies: grant site access and basic functionality, for example, access to personal accounts.
    Functional cookies: allow us to test and analyze how audiences interact with our Website and choices they made (session keys, languages or regions), so that we can optimize the Website based on visitors’ behavior.
    Advertising cookies: allow us to measure our content marketing effectiveness. These cookies are provided by our partners to track our visitors and measure ad campaign effectiveness. We do not disclose your personal data (such as name or email address) to affiliate partners, except for those collected by advertising cookies.
    However, your data may be linked to other personal information obtained by other providers. The latter type of external data processing is subject to notifications and privacy policies of third party providers. In addition, several third-party providers also install cookies on the Website in order to provide us with their services. Such services include, but are not limited to, improving your website navigation, tracking your activities, evaluating Website performance and our advertising effectiveness.
    Most online browsers automatically accept cookies. You can block some or all cookies or delete those already installed by modifying your browser settings. However, we don’t recommend blocking or deleting cookies, as this may limit access to our Website.

Your Rights

  • You may have the right to access, erase, restrict the use of your Personal Data, object to certain processing, withdraw consent where processing is based on consent, object to direct marketing, and lodge a complaint with a competent supervisory authority. These rights are not absolute and may be limited where processing is required for legal, regulatory, AML, licensing, fraud prevention, responsible gaming, dispute resolution, security or legal claim purposes. We may extend the response period or refuse to act on unfounded, excessive or repetitive requests where permitted by law.
    To exercise your rights, please contact Customer Support using the details in Section 5.

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This website owned and operated by a company registered in the Republic of Cyprus, with its principal place of business at Nicosia, Cyprus. All gambling services are provided by parent company, with its registered address at Curacao. The website is operated under eGaming License, issued Authorized and Regulated by the Government of Curacao.