Your Data, Handled Responsibly

1. Who Controls Your Data

The data controller for all personal information collected through spin-polo.casino is Spinpolo Entertainment N.V., registered in Curacao. For UK-resident users, Spin Polo applies the standards set out in the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 as a matter of policy, even though Spin Polo is not itself established in the UK. Our Data Protection contact is [email protected].

2. Data We Collect

We collect personal data in the following categories:

• Registration data: name, date of birth, email address, phone number, postal address, username
• Verification data: copies of government-issued ID, proof of address, payment method documentation, source of funds information
• Financial data: deposit and withdrawal history, transaction references, payment method details (stored by PCI-DSS compliant processors, not on Spin Polo servers)
• Gameplay data: game history, session durations, bet sizes, win/loss records
• Device and technical data: IP address, browser type, operating system, device identifiers, cookies and similar tracking data
• Communications data: live chat transcripts, email correspondence, support ticket records
• Responsible gambling data: self-imposed limits, time-out and exclusion records

3. Lawful Basis for Processing

4. Cookies

Spin Polo uses the following categories of cookies:

• Strictly necessary: session management, login state, security tokens; these cannot be opted out of as they are essential to the platform's operation
• Functional: language preferences, game lobby filter settings, remembered username; these persist between sessions to improve your experience
• Analytics: aggregated usage statistics collected by tools such as Google Analytics (anonymised IP); can be opted out via the cookie banner
• Marketing: advertising and affiliate tracking cookies (e.g. Facebook Pixel, Google Ads conversion); only set with your consent

You can manage cookie preferences at any time via the cookie settings link in the footer. Withdrawing consent for non-essential cookies does not affect the platform's core functionality.

5. Third-Party Data Processors

Spin Polo shares personal data with trusted third-party processors only where necessary. All processors are contractually bound to handle data in accordance with UK GDPR standards:

• Game providers (Evolution, Pragmatic Play, NetEnt, Play'n GO and others): receive anonymised player session tokens sufficient to deliver game functionality; no name or payment data is shared
• Payment gateways (Visa, Mastercard network processors, crypto payment processors): receive payment credentials solely for transaction processing via PCI-DSS compliant infrastructure
• KYC and AML vendors (identity verification and sanctions screening services): receive copies of ID documents and personal data for verification against regulatory databases
• Email and CRM platforms: receive email address and preference data solely to send transactional and marketing communications to opted-in users
• Fraud and security vendors: receive device fingerprint and IP data for fraud scoring purposes

6. Data Retention

We retain personal data for as long as your account is active and for a minimum of 5 years after account closure to meet our AML and regulatory reporting obligations. KYC documents are retained for 5 years post-closure as required by Curacao GCB licence conditions. Marketing preferences are retained only while you remain opted in and are deleted within 30 days of an opt-out request. Anonymised analytics data may be retained indefinitely as it cannot be attributed to any individual.

7. Your Rights Under UK GDPR

If you are a UK resident, the following rights are available to you in connection with your personal data:

• Right of access: request a copy of the personal data we hold about you (subject access request)
• Right to rectification: request correction of inaccurate or incomplete data
• Right to erasure: request deletion of your data where it is no longer necessary or processed on the basis of consent (subject to our legal retention obligations)
• Right to portability: receive your data in a structured, machine-readable format
• Right to restrict processing: ask us to pause processing of your data pending a dispute or correction
• Right to object: object to processing carried out under legitimate interests, including profiling
• Right to withdraw consent: where processing is based on consent (e.g. marketing), withdraw at any time without affecting prior processing

To exercise any of these rights, email [email protected] with your username and the specific right you wish to exercise. We respond within 30 days. If you are not satisfied with our response, you may complain to the UK Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.