spin ph Privacy Policy

1 Introduction and Scope

This Privacy Policy ("Policy") describes how spin ph ("we," "us," "our," or "the Platform") collects, uses, stores, and discloses personal data relating to individuals ("you," "your," or "Data Subject") who access or use the spin ph website at https://spin-ph.net and all associated services, games, and features.

This Policy applies to all registered players and visitors of spin ph, including those accessing the Platform from Metro Manila, Cebu, Davao, Quezon City, Makati, and all other locations within the Philippines. It covers personal data collected through the website, mobile browser access, customer support interactions, and any other channel through which you interact with spin ph.

By registering an account or continuing to use the spin ph platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must discontinue use of the Platform.

2 Data Controller Information

spin ph acts as the data controller in respect of the personal data it collects and processes in connection with the operation of the Platform. As data controller, spin ph determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data protection law, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

For all data privacy inquiries, requests, or complaints, you may contact our designated Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

3 Personal Data We Collect

spin ph collects the following categories of personal data from players and visitors:

3.1 Registration and Identity Data

• Full legal name
• Date of birth (for age verification — players must be 21 or older)
• Gender
• Nationality and country of residence
• Username and password (stored in encrypted form)
• Email address
• Mobile phone number

3.2 KYC Verification Data

• Government-issued photo ID (e.g., Philippine passport, SSS ID, UMID, driver's license, PhilSys national ID)
• Proof of address (e.g., utility bill, bank statement issued within the last three months)
• Selfie or live photo for identity matching purposes
• Source of funds documentation where required by anti-money laundering regulations

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records
• Payment method details (e.g., GCash mobile number, PayMaya account reference, BPI/BDO/Metrobank account details — stored in tokenized or masked form)
• Account balance history
• Bonus and promotional transaction records

3.4 Gaming Activity Data

• Game session logs (games played, wagers placed, outcomes, session duration)
• Betting history across all spin ph game categories
• Responsible gaming tool usage (deposit limits set, cool-off periods activated, self-exclusion requests)

3.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Cookie identifiers and session tokens
• Pages visited, time spent on page, and click-path data

3.6 Communications Data

• Customer support chat transcripts and email correspondence
• Feedback and survey responses
• Marketing preference records (opt-in and opt-out history)

Data Category	Examples	Required?
Identity	Name, date of birth, email, phone	Mandatory for registration
KYC Documents	Government ID, proof of address	Mandatory for withdrawals
Financial	Payment method, transaction history	Mandatory for deposits/withdrawals
Gaming Activity	Bets placed, game sessions, outcomes	Automatically collected
Technical	IP address, device info, cookies	Automatically collected
Communications	Support chats, email correspondence	Collected when you contact us

4 How We Collect Your Data

spin ph collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey.
• Automatically: Through cookies, web beacons, server logs, and similar tracking technologies when you browse or interact with the spin ph platform.
• From third parties: From KYC verification service providers, payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), fraud detection services, and regulatory databases where permitted by law.

5 How We Use Your Data

spin ph uses your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your spin ph player account.
• Identity and age verification: Confirming that you meet the 21+ age requirement and verifying your identity in compliance with KYC obligations.
• Payment processing: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other accepted payment methods.
• Game delivery: Providing access to spin ph's full game library, including slots, bingo, fishing games, and live casino titles.
• Regulatory compliance: Meeting our obligations under Philippine anti-money laundering laws, PAGCOR regulations, and the Data Privacy Act of 2012.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, and other security threats.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior and administering responsible gaming tools such as deposit limits and self-exclusion.
• Customer support: Responding to your inquiries, resolving disputes, and improving our support services.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates — only where you have opted in to receive such communications. You may opt out at any time.
• Platform improvement: Analyzing aggregated usage data to improve the spin ph platform, game selection, and user experience.

6 Legal Basis for Processing

spin ph processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing required to perform our contract with you — including account registration, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate interests: Processing carried out for spin ph's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Sharing Your Data

spin ph does not sell, rent, or trade your personal data. We may share your data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• KYC and identity verification providers: Third-party services that assist in verifying your identity and age during the account registration and withdrawal process.
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers necessary to process your deposits and withdrawals.
• Fraud detection and security services: Providers that help spin ph detect and prevent fraudulent activity, money laundering, and unauthorized access.
• IT and hosting providers: Cloud infrastructure and data hosting providers that store and process Platform data on spin ph's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities where disclosure is required by law or court order.
• Professional advisors: Lawyers, auditors, and accountants where necessary for legal, compliance, or financial purposes, subject to professional confidentiality obligations.

8 Cookies and Tracking Technologies

spin ph uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyze usage patterns, and support security functions. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled without affecting Platform functionality.
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations.
• Analytics cookies: Collect aggregated, anonymized data about how players use the Platform, helping spin ph identify areas for improvement.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorized login attempts.

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the spin ph platform. spin ph does not use third-party advertising or behavioral tracking cookies.

9 Data Retention

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

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering record-keeping requirements.
• KYC documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Financial and transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLC and tax record-keeping obligations.
• Gaming activity logs: Retained for a minimum of three (3) years from the date of the session, for regulatory audit and responsible gaming purposes.
• Customer support records: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing preference records: Retained until you withdraw consent or close your account, plus one (1) year for audit purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized. Where data is anonymized, it may be retained indefinitely for statistical and analytical purposes.

10 Data Security

spin ph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the spin ph platform.
• Encryption of sensitive data at rest, including passwords (stored as salted hashes) and payment method details (stored in tokenized form).
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, vulnerability scanning, and penetration testing of Platform infrastructure.
• Multi-factor authentication options for player accounts.
• Continuous monitoring for suspicious activity, unauthorized access attempts, and data anomalies.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

11 Your Rights as a Data Subject

Under the Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights in relation to your personal data held by spin ph:

• Right to be informed: The right to know what personal data spin ph collects about you and how it is used — as set out in this Policy.
• Right of access: The right to request a copy of the personal data spin ph holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: 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 spin ph's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact spin ph's Data Protection Officer using the contact details in Section 14. spin ph will respond to all verified data subject requests within fifteen (15) business days of receipt.

12 Children and Minors

The spin ph platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. spin ph does not knowingly collect personal data from individuals under the age of 21.

If spin ph becomes aware that personal data has been collected from an individual under the age of 21, the relevant account will be immediately suspended, all associated data will be reviewed, and the matter will be handled in accordance with spin ph's underage gambling policy as set out in the Terms & Conditions.

If you are a parent or guardian and believe that your child has registered an account with spin ph, please contact our support team immediately so that appropriate action can be taken.

13 Changes to This Policy

spin ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform operations. When material changes are made, spin ph will notify registered players via the email address associated with their account and/or by displaying a prominent notice on the Platform prior to the changes taking effect.

The revised Policy will display an updated "Last Updated" date at the top of this page. Your continued use of the spin ph platform after the effective date of any amendment constitutes your acknowledgment of the revised Policy. We encourage you to review this page periodically to stay informed about how spin ph protects your personal data.

14 Contact and Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way spin ph handles your personal data, please contact our Data Protection Officer:

Email: [email protected]

General Support: [email protected]

You may also reach our support team 24 hours a day, 7 days a week via live chat on the spin ph platform. Our Filipino-speaking agents are available to assist with data privacy inquiries in English.

If you are not satisfied with spin ph's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines through its official channels.