Privacy Policy – SpinPlay Online Casino Philippines

This Privacy Policy is issued by SpinPlay ("SpinPlay", "we", "us", "our"), the operator of the online gaming platform accessible at spinplay.best. SpinPlay is a PAGCOR-licensed gaming operator serving players in the Philippines. We are the data controller responsible for your personal information as defined under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, or "DPA").

This Policy applies to all personal data we collect from you when you:

• Register an account on SpinPlay
• Make a deposit or withdrawal using GCash, Maya, or any other supported Philippine payment method
• Play any game on the SpinPlay platform — Tongits, Pusoy, Color Game, Jackpot Slots, Sports Betting, Football Betting, or Virtual Sports
• Contact our customer support team
• Participate in promotions, tournaments, or any other SpinPlay programme
• Browse the SpinPlay website, even without logging in

By using SpinPlay's services, you acknowledge that you have read this Privacy Policy and understand how your data will be handled. If you do not agree, please do not register or continue using the platform.

SpinPlay collects personal data in two broad categories: data you provide directly, and data collected automatically when you use our platform.

SpinPlay does not collect sensitive personal information such as racial or ethnic origin, religious beliefs, political opinions, health records, or sexual orientation unless this is strictly required by law (for example, certain anti-money laundering checks) and you have given explicit consent.

SpinPlay collects personal data through the following channels:

• Direct input from you: When you fill in the registration form, upload identity documents, contact support, respond to a survey, or enter payment details to top up your account via GCash, Maya, or other Philippine payment methods.
• Automatic collection: When you access SpinPlay's website or play any game, our servers automatically record technical data including your IP address, device information, browser type, and session activity. This happens through cookies, server logs, and similar technologies described in Section 9.
• Third-party payment processors: When you make a deposit or withdrawal, your payment provider (such as GCash, Maya, or your bank) shares transaction confirmation data with SpinPlay necessary to credit or debit your account. SpinPlay does not store your full e-wallet PIN or bank login credentials.
• Identity verification partners: SpinPlay may use regulated third-party KYC (Know Your Customer) verification services to verify the authenticity of documents you submit. These services process your data under their own privacy policies, which comply with Philippine law.
• Publicly available sources: In limited circumstances, SpinPlay may verify information against publicly available Philippine government databases or court records in connection with anti-money laundering or fraud prevention obligations.

SpinPlay only uses your personal data for specific, legitimate purposes. We do not use your data in ways that are inconsistent with the purposes described here without your prior consent. The main purposes are:

• Account management: To create and maintain your SpinPlay player account, verify your identity, authenticate your logins, and manage account security.
• Payment processing: To process deposits from and withdrawals to your GCash, Maya, BDO, BPI, UnionBank, or other connected Philippine payment method. Transaction records are maintained as required by law.
• Game provision: To operate the SpinPlay platform and deliver all game services — Tongits, Pusoy, Color Game, Jackpot Slots, Sports Betting, Football Betting, and Virtual Sports.
• Legal compliance: To comply with PAGCOR licensing requirements, anti-money laundering (AMLA) obligations, Know Your Customer (KYC) rules, and any other applicable Philippine law.
• Responsible gaming: To monitor gameplay patterns for signs of problem gambling and to administer deposit limits, self-exclusion, and cool-off periods that you have set or that SpinPlay has applied under its duty of care.
• Fraud and security: To detect, investigate, and prevent fraudulent activity, multi-accounting, bonus abuse, and other prohibited conduct described in our Terms and Conditions.
• Customer support: To respond to your queries, process complaints, and improve the quality of our support based on interaction records.
• Marketing communications: To send you relevant promotions, bonus offers, and platform updates — but only where you have opted in and where you have not since opted out. You can unsubscribe from marketing emails at any time.
• Platform improvement: To analyse usage data and improve SpinPlay's features, game performance, and user experience for Filipino players.

Under the Philippine Data Privacy Act, SpinPlay must have a valid legal basis for each type of data processing it carries out. SpinPlay relies on the following bases:

• Contractual necessity: Processing required to fulfil our agreement with you — operating your account, processing your transactions, and delivering game services. Without this processing, SpinPlay cannot provide its services to you.
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, tax requirements, and other Philippine laws applicable to licensed gaming operators.
• Legitimate interests: Processing carried out for SpinPlay's legitimate business interests, including fraud prevention, platform security, and service improvement — where these interests are not overridden by your privacy rights.
• Consent: For marketing communications and certain optional data uses, SpinPlay relies on your explicit consent, which you may withdraw at any time.

SpinPlay does not sell your personal data to any third party. We may share your data with the following categories of recipients, strictly on a need-to-know basis and only for the purposes described in this Policy:

• Payment service providers: GCash, Maya, GrabPay, Coins.ph, BDO, BPI, UnionBank, and Visa/Mastercard networks — to process your deposits and withdrawals. These providers are regulated financial institutions operating under Philippine law.
• Identity verification services: Third-party KYC providers who process identity document scans to verify your eligibility and comply with PAGCOR requirements. All such providers are bound by data processing agreements and are required to comply with the DPA.
• Game software providers: Third-party game developers whose titles appear on the SpinPlay platform may receive aggregated, anonymised gameplay data for game performance analysis. They do not receive personally identifiable information.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and Philippine law enforcement agencies — where disclosure is required by law, court order, or regulatory request.
• Professional advisors: Lawyers, accountants, and auditors engaged by SpinPlay, who are bound by professional confidentiality obligations.
• Technology infrastructure providers: Cloud hosting and cybersecurity vendors who process data on SpinPlay's behalf under strict data processing agreements. These vendors do not have independent access to use your data.

SpinPlay does not keep your data longer than necessary. Retention periods are set based on the purpose of collection and applicable legal requirements:

• Account data: Retained for the duration of your account and for 5 years after account closure, in line with PAGCOR record-keeping requirements and AMLA obligations.
• Transaction records: Retained for 10 years from the date of the transaction, as required by Philippine AMLA regulations for licensed gaming operators.
• KYC and identity documents: Retained for 5 years after account closure or the last transaction, whichever is later.
• Customer support communications: Retained for 3 years from the date of the last interaction to assist with disputes and service improvement.
• Marketing preferences and consent records: Retained for the duration of your account relationship and for 1 year after you withdraw consent, as evidence of lawful processing.
• Technical and usage logs: Retained for 12 months and then automatically deleted or anonymised.

After the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to you as an individual.

SpinPlay takes the security of your personal data seriously. We implement a layered set of technical and organisational security measures:

• 256-bit SSL/TLS encryption: All data transmitted between your device and SpinPlay's servers is encrypted using the same standard used by major Philippine banks and financial institutions.
• Encrypted data storage: Sensitive personal data — including identity documents and financial information — is stored in encrypted form. Even in the unlikely event of a breach, encrypted data cannot be read without the corresponding decryption key.
• Two-factor authentication (2FA): SpinPlay supports 2FA for player account logins to provide an additional layer of security beyond your password.
• Access controls: Access to personal data within SpinPlay is restricted on a strict need-to-know basis. Staff with access rights are subject to confidentiality obligations and regular security training.
• Penetration testing and security audits: SpinPlay undergoes periodic third-party security testing to identify and address vulnerabilities before they can be exploited.
• Fraud monitoring: SpinPlay operates 24/7 automated fraud monitoring systems that detect unusual account activity and flag potential security incidents for immediate review.

Despite these measures, no system is 100% impenetrable. If SpinPlay becomes aware of a data breach that poses a risk to your rights, we will notify affected players and the National Privacy Commission (NPC) within the timeframe required by Philippine law.

SpinPlay uses cookies and similar technologies to operate the platform, remember your preferences, analyse usage, and — where you have consented — deliver relevant marketing. A cookie is a small text file stored on your device when you visit a website. It does not give SpinPlay access to your device or files.

The categories of cookies SpinPlay uses are described below. You can manage your cookie preferences through your browser settings at any time, though disabling some cookies may affect platform functionality:

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by SpinPlay. To exercise any of these rights, contact our Data Privacy Officer (DPO) at support@spinplay.best with the subject line "Data Rights Request":

SpinPlay's services are strictly for adults aged 18 and above. SpinPlay does not knowingly collect personal data from anyone under the age of 18. If you are a parent or guardian and believe that a minor has registered on SpinPlay using your details or their own, please contact us immediately at support@spinplay.best with the subject line "Minor Account Report".

SpinPlay will immediately investigate the report, suspend the account in question, and delete any personal data collected from the minor, subject to any data we are legally required to retain as evidence of the violation. Any balance in the minor's account will be returned to the payment method used for the original deposit.

SpinPlay employs age verification checks at registration and during the KYC process. We take underage gambling seriously and will cooperate fully with any regulatory investigation related to a minor accessing our platform.

SpinPlay may update this Privacy Policy from time to time to reflect changes in the law, our data practices, or the platform's services. When we make material changes — meaning changes that significantly affect how we handle your personal data — we will notify you by email to your registered address and display a prominent notice on the SpinPlay platform at least 14 days before the change takes effect.

Minor changes (such as formatting corrections or clarifications that do not alter how your data is used) may be made without prior notice. The "Last Updated" date at the top of this page will always reflect when the most recent version was published.

Your continued use of SpinPlay after a Privacy Policy update takes effect constitutes your acknowledgement of the updated Policy. If you do not accept any changes, you may close your account by contacting our support team.

SpinPlay has appointed a Data Privacy Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and managing data rights requests. If you have any questions about this Privacy Policy, wish to exercise your data rights, or want to report a privacy concern, contact our DPO through any of the channels below: