spin ph Privacy Policy

This Privacy Policy ("Policy") describes how spin ph ("spin ph," "we," "us," or "our"), the operator of the online gaming platform at spinph.lat, collects, uses, discloses, retains, and protects personal information in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and applicable guidelines issued by the National Privacy Commission (NPC) of the Philippines.

This Policy applies to all personal data processed by spin ph in connection with your registration, use of the platform, participation in games, processing of transactions, and any other interaction you have with spin ph — whether via the website, live chat, email, or any other channel. By creating a spin ph account or using the platform, you acknowledge that you have read and understood this Policy.

Where spin ph acts as a data processor on behalf of a third-party data controller (for example, game providers who supply their own RNG-certified platforms), processing activities are governed by a separate Data Processing Agreement between spin ph and that controller.

spin ph collects only the data necessary for the lawful operation of an online gaming platform in the Philippines. The categories of personal data we collect are described below:

spin ph does not collect sensitive personal information as defined under the DPA (such as racial or ethnic origin, religious beliefs, health data, or political opinions) unless specifically required by applicable law or regulatory obligation and only with your express consent.

spin ph uses your personal data for the following purposes:

1. Account Creation and Management: To register your account, verify your identity, maintain your player profile, and communicate account-related information.
2. Payment Processing: To process deposits, withdrawals, and any bonus payments; to verify that payment methods belong to the registered account holder; and to maintain accurate financial records.
3. Regulatory Compliance: To comply with PAGCOR licensing conditions, Anti-Money Laundering Act (AMLA) obligations, KYC requirements, and NPC data governance standards.
4. Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, bonus abuse, money laundering, unauthorized account access, and other security threats.
5. Responsible Gaming: To monitor gaming patterns, administer self-imposed limits, and identify players who may be at risk of problem gambling in accordance with spin ph's Responsible Gaming obligations.
6. Customer Support: To respond to your queries, complaints, and requests; to maintain records of support interactions for quality assurance and dispute resolution.
7. Platform Improvement: To analyze aggregated, anonymized usage data to improve site performance, game selection, and user experience. No individual profiling is conducted for this purpose.
8. Marketing Communications: To send you information about promotions, bonuses, and new games on spin ph — only if you have opted in to receive such communications. You may opt out at any time by contacting support.

Under the Data Privacy Act of 2012 and its IRR, spin ph processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our obligations under the Terms and Conditions you accepted when registering — including account management, payment processing, and gameplay services.
• Legal Obligation: Processing required to comply with Philippine law, including PAGCOR regulations, AMLA obligations, and NPC directives.
• Legitimate Interests: Processing for fraud prevention, security monitoring, and platform improvement, where our legitimate interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for optional marketing communications and for any non-essential cookies, where your prior opt-in consent has been obtained. You may withdraw consent at any time.

spin ph does not sell, rent, or trade your personal information. We may share your data only in the following limited circumstances:

1. Payment Service Providers: GCash (G-Xchange, Inc.), Maya (Voyager Innovations, Inc.), BPI, BDO, Metrobank, and similar providers — only the data strictly necessary to process your transaction.
2. Game Technology Providers: Third-party game studios (e.g., JILI, PG Soft, Pragmatic Play) receive session tokens and anonymized player identifiers necessary to run their games. No personally identifiable data beyond what is required for game integrity is transmitted.
3. Identity Verification Partners: Third-party KYC and AML screening services that assist in verifying your identity and screening against regulatory watchlists, bound by confidentiality and data processing agreements.
4. Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or any other Philippine government authority with lawful jurisdiction — when required by law or valid legal process.
5. Professional Advisers: Lawyers, accountants, auditors, and insurers in the course of providing professional services to spin ph, subject to confidentiality obligations.
6. Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all assets, your data may be transferred to the acquiring entity, which will be bound by this Policy or a materially equivalent one.

All third-party processors engaged by spin ph are contractually obligated to process your data only as instructed, to implement appropriate security measures, and to comply with the DPA and applicable Philippine data protection requirements.

The spin ph website uses cookies and similar technologies to operate core platform functions and to analyze site performance. The categories of cookies we use are:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies and security tokens. These cannot be disabled.
• Performance & Analytics Cookies: Anonymized data on how players navigate the site, which pages are most visited, and where errors occur. Used solely to improve site performance. No individual profiling.
• Functional Cookies: Remember your preferences such as language settings and login state. These improve your experience but are not essential to platform operation.

spin ph does not use third-party advertising cookies or behavioural tracking cookies that profile you across external websites. Your browser settings allow you to manage or delete cookies; however, disabling strictly necessary cookies will prevent you from logging in or using the platform.

spin ph retains your personal data for the minimum period necessary to fulfil the purposes for which it was collected, subject to the following retention schedule:

• Active Account Data: Retained for the duration of your account relationship with spin ph, plus a minimum of 5 years following account closure to comply with AMLA record-keeping requirements.
• Transaction Records: Retained for a minimum of 10 years in accordance with AMLC and PAGCOR regulatory requirements applicable to online gaming operators.
• KYC Documents: Retained for the duration of the account relationship plus 5 years post-closure, or longer if required by applicable law.
• Support Communications: Retained for 2 years from the date of the last interaction, used for dispute resolution and quality assurance.
• Marketing Preferences: Retained until you withdraw consent, after which your opt-out preference is retained indefinitely to prevent inadvertent re-contact.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC guidelines on personal data disposal.

spin ph implements a layered security architecture to protect your personal data from unauthorized access, alteration, disclosure, or destruction. Key technical and organizational measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and spin ph servers;
• AES-256 encryption for sensitive data at rest, including KYC document storage;
• Multi-factor authentication requirements for internal administrative access to player data systems;
• Role-based access controls ensuring that only authorized personnel with a legitimate operational need can access personal data;
• Regular third-party penetration testing and vulnerability scanning of all platform systems;
• An incident response plan aligned with NPC breach notification requirements under Section 20 of the DPA.

Despite these measures, no internet-based system is completely immune to security incidents. In the event of a personal data breach that poses a real risk to your rights and freedoms, spin ph will notify you and the NPC within 72 hours of becoming aware of the breach, in accordance with NPC Circular 16-03.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by spin ph:

To exercise any of the above rights, please contact the spin ph Data Protection Officer (DPO) via live chat or email at [email protected] with the subject line "Data Privacy Request." Requests will be acknowledged within 5 business days and resolved within 30 calendar days. Identity verification may be required before processing your request.

If you believe your data rights have been violated, you may file a complaint with the National Privacy Commission (NPC) at privacy.gov.ph.

The spin ph platform is strictly for individuals aged 21 years and above for casino-style gaming, consistent with PAGCOR regulations. spin ph does not knowingly collect personal data from individuals under 21. If we become aware that personal data has been collected from a person under the minimum age, that data will be deleted immediately and the associated account closed.

If you have reason to believe that a minor has registered on the spin ph platform, please contact us immediately at [email protected] so we can investigate and take prompt action.

Some of spin ph's service providers and game technology partners are located outside the Philippines. When personal data is transferred to a jurisdiction outside the Philippines, spin ph ensures that such transfers are conducted in accordance with Section 21 of the DPA and NPC guidelines on cross-border data flows.

Appropriate safeguards include contractual data processing agreements incorporating the NPC's standard contractual clauses, and in some cases, reliance on the adequacy determination or equivalent protections provided by the receiving country's data protection framework. A list of countries to which data may be transferred is available upon request from the DPO.

spin ph may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory requirements. When we make material changes, we will notify registered players via the email address or mobile number on file, and/or by publishing a prominent notice on the spin ph website, at least 14 days before the changes take effect.

The "Effective date" at the top of this Policy reflects the date of the most recent revision. Your continued use of the spin ph platform following the effective date of any updated Policy constitutes your acknowledgment of the changes. If you do not agree to the updated Policy, you must stop using the platform and may request account closure.

spin ph has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and the Data Privacy Act of 2012. You may contact the spin ph DPO through the following channels:

Live Chat: Available 24/7 on the spin ph website — fastest channel for general queries.
Email (DPO): [email protected] — use subject line "Data Privacy Request" or "DPO Enquiry."
Response Time: Acknowledgement within 5 business days; full resolution within 30 calendar days.

For complaints that cannot be resolved directly with spin ph, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.