Privacy Policy

Spinago Casino ("Spinago," "we," "us," or "our") is committed to protecting the privacy and security of personal information collected from users ("you" or "your") of our online casino platform. This Privacy Policy explains how Spinago collects, uses, discloses, and safeguards your personal data when you access or use our services in Australia.

By creating an account with Spinago Casino or using our services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with this policy, please do not use our services.

1. Information We Collect

1.1 Personal Information

When you register for a Spinago account or use our services, we collect the following categories of personal information:

Account Registration Data:

• Full name (first name and surname)
• Date of birth
• Email address
• Phone number
• Residential address (street, city, state, postcode)
• Country of residence (Australia)
• Username and password
• Preferred currency (AUD)

Identity Verification Data:

• Government-issued identification documents (driver's license, passport)
• Proof of address documents (utility bills, bank statements)
• Photographic identification for age verification
• Biometric data (if required for enhanced verification)

Financial Information:

• Payment method details (credit/debit card numbers, bank account information)
• Transaction history (deposits, withdrawals, wagers)
• Payment processor information
• Cryptocurrency wallet addresses (if applicable)

1.2 Automatically Collected Information

When you access Spinago Casino, we automatically collect certain technical information:

• IP address and geographic location
• Device information (device type, operating system, browser type)
• Log data (access times, pages viewed, clickstream data)
• Cookies and similar tracking technologies
• Session duration and gameplay statistics
• Referral sources and marketing attribution data

1.3 Gaming and Behavioral Data

To provide personalized services and ensure responsible gaming, Spinago collects:

• Game preferences and play history
• Betting patterns and wagering amounts
• Win/loss records and account balance fluctuations
• Self-exclusion and responsible gambling settings
• Customer support interactions and communications

1.4 Communications Data

• Email correspondence with Spinago support
• Live chat transcripts
• Phone call recordings (with your consent)
• Survey responses and feedback

2. How We Use Your Information

Spinago Casino uses your personal information for the following purposes:

2.1 Service Provision

• Creating and managing your Spinago account
• Processing deposits, withdrawals, and financial transactions
• Providing access to casino games and gaming services
• Verifying your identity and age (18+ requirement in Australia)
• Maintaining accurate account records

2.2 Legal and Regulatory Compliance

• Complying with Australian gambling laws and regulations
• Fulfilling Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations
• Preventing fraud, money laundering, and criminal activity
• Responding to legal requests and court orders
• Reporting to regulatory authorities when required

2.3 Responsible Gaming

• Monitoring gameplay patterns for signs of problem gambling
• Implementing deposit limits and self-exclusion measures
• Providing responsible gambling tools and resources
• Enforcing underage gambling prevention measures

2.4 Customer Support

• Responding to inquiries submitted via Spinago login portal
• Resolving disputes and technical issues
• Providing personalized customer assistance
• Improving service quality based on feedback

2.5 Marketing and Communications

• Sending promotional offers and bonuses (with your consent)
• Providing updates about Spinago Australia services
• Conducting market research and surveys
• Personalizing marketing content based on preferences

2.6 Platform Improvement

• Analyzing usage patterns to enhance user experience
• Developing new features and gaming content
• Conducting security audits and vulnerability assessments
• Optimizing website performance and functionality

3. Legal Basis for Processing

Spinago Casino processes your personal information based on the following legal grounds:

4. Data Sharing and Disclosure

Spinago Casino may share your personal information with third parties under the following circumstances:

4.1 Service Providers

We engage trusted third-party service providers to support Spinago Casino operations:

• Payment Processors: To facilitate deposits and withdrawals (e.g., credit card processors, e-wallet providers, cryptocurrency payment gateways)
• Identity Verification Services: To conduct KYC checks and age verification
• Gaming Software Providers: To deliver casino games and gaming content
• Cloud Hosting Services: To store and process data securely
• Customer Support Platforms: To manage support tickets and live chat
• Marketing and Analytics Tools: To deliver targeted campaigns and analyze user behavior

All service providers are contractually obligated to protect your data and use it solely for providing services to Spinago.

4.2 Regulatory Authorities

We may disclose information to Australian regulatory bodies and law enforcement agencies when:

• Required by law or legal process
• Responding to government requests or court orders
• Reporting suspicious transactions under AML regulations
• Cooperating with investigations into illegal activity

4.3 Business Transfers

In the event of a merger, acquisition, or sale of Spinago Casino assets, your personal information may be transferred to the acquiring entity. You will be notified of any such change in ownership.

4.4 Fraud Prevention Networks

We participate in fraud prevention databases and share information with other gambling operators to detect and prevent fraudulent activity, bonus abuse, and multiple account creation.

4.5 Legal Obligations

Spinago may disclose your information to:

• Comply with Australian gambling laws and regulations
• Protect the rights, property, or safety of Spinago, our users, or the public
• Enforce our Terms and Conditions
• Defend against legal claims or disputes

4.6 With Your Consent

We may share your information with third parties when you explicitly consent to such disclosure (e.g., participating in affiliate programs or promotional partnerships).

5. International Data Transfers

Spinago Casino operates internationally, and your personal information may be transferred to, stored in, or processed in countries outside Australia. These transfers are necessary to provide our services and may include:

• Cloud storage facilities in jurisdictions with robust data protection laws
• Gaming software providers based in regulated European markets
• Payment processors operating globally
• Customer support centers in various time zones

When transferring data internationally, Spinago ensures adequate protection through:

• Standard Contractual Clauses (SCCs) approved by data protection authorities
• Data processing agreements requiring equivalent security standards
• Transfers to countries with adequacy decisions (e.g., EU member states)
• Binding corporate rules for intra-group transfers

For Australian residents, we ensure compliance with the Australian Privacy Principles (APPs) regarding cross-border data transfers.

6. Data Security

Spinago Casino employs industry-leading security measures to protect your personal information:

6.1 Technical Security Measures

• Encryption: 256-bit SSL/TLS encryption for data transmission; AES-256 encryption for data at rest
• Secure Servers: Data stored in ISO 27001-certified data centers with physical security controls
• Firewalls: Multi-layered firewall protection to prevent unauthorized access
• Access Controls: Role-based access restrictions; multi-factor authentication for employee access
• Intrusion Detection: Real-time monitoring for suspicious activity and security breaches
• Regular Security Audits: Independent third-party penetration testing and vulnerability assessments

6.2 Organizational Security Measures

• Strict confidentiality agreements for all employees and contractors
• Mandatory security training for staff handling personal data
• Data minimization principles (collecting only necessary information)
• Regular security policy reviews and updates
• Incident response plan for data breaches

6.3 Account Security

You are responsible for maintaining the security of your Spinago login credentials. We recommend:

• Using a strong, unique password (minimum 8 characters, including uppercase, lowercase, numbers, and symbols)
• Enabling two-factor authentication (2FA) on your account
• Never sharing your login credentials with third parties
• Logging out after each session, especially on shared devices
• Reporting suspicious account activity immediately to Spinago support

6.4 Data Breach Notification

In the unlikely event of a data breach affecting your personal information, Spinago will:

• Notify affected users within 72 hours of becoming aware of the breach
• Inform relevant Australian regulatory authorities as required by law
• Provide details about the nature of the breach and compromised data
• Outline remedial measures taken and recommended actions for affected users

7. Data Retention

Spinago Casino retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal obligations.

7.1 Retention Periods

7.2 Data Deletion

After the applicable retention period expires, Spinago will securely delete or anonymize your personal information unless:

• Retention is required to comply with legal obligations
• Data is necessary to establish, exercise, or defend legal claims
• You have consented to extended retention

8. Your Privacy Rights

As a user of Spinago Casino in Australia, you have the following rights regarding your personal information:

8.1 Right to Access

You have the right to request a copy of the personal information Spinago holds about you. To exercise this right, submit a written request through your Spinago login account or contact our Data Protection Officer. We will provide the information within 30 days of verification.

8.2 Right to Rectification

If your personal information is inaccurate or incomplete, you can:

• Update your details directly in your Spinago account settings
• Contact customer support to request corrections
• Provide updated documentation for identity verification data

8.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal information under certain circumstances:

• The data is no longer necessary for the purposes it was collected
• You withdraw consent for processing (where consent was the legal basis)
• You object to processing and there are no overriding legitimate grounds
• The data has been unlawfully processed

Note: Spinago may be unable to delete certain data due to legal retention obligations (e.g., financial records, KYC documents) for up to 7 years after account closure.

8.4 Right to Restriction of Processing

You can request that Spinago limits how we use your personal information if:

• You contest the accuracy of the data (during verification period)
• Processing is unlawful, but you oppose deletion
• Spinago no longer needs the data, but you require it for legal claims
• You have objected to processing pending verification of legitimate grounds

8.5 Right to Data Portability

Where technically feasible, you can request your personal information in a structured, machine-readable format (e.g., CSV, JSON) for transfer to another service provider. This applies to data you provided to Spinago based on consent or contract.

8.6 Right to Object

You have the right to object to:

• Marketing Communications: Opt out of promotional emails via unsubscribe links or account settings
• Profiling and Automated Decision-Making: Request human review of automated decisions affecting you
• Processing Based on Legitimate Interests: Object to processing unless Spinago demonstrates compelling legitimate grounds

8.7 Right to Withdraw Consent

Where processing is based on consent (e.g., marketing communications), you can withdraw consent at any time. This does not affect the lawfulness of processing before withdrawal.

8.8 Right to Lodge a Complaint

If you believe Spinago has violated your privacy rights, you can:

• Contact our Data Protection Officer (contact details below)
• Lodge a complaint with the Office of the Australian Information Commissioner (OAIC)
• Seek remedies through Australian courts

8.9 Exercising Your Rights

To exercise any of these rights:

1. Log in to your Spinago Australia account and access privacy settings
2. Submit a written request via email to our Data Protection Officer
3. Provide proof of identity (for security purposes)
4. Specify the right you wish to exercise and the data involved

Spinago will respond to your request within 30 days. If more time is needed, we will inform you of the extension (up to 60 additional days) and the reason for the delay.

9. Cookies and Tracking Technologies

9.1 Types of Cookies Used

Spinago Casino uses cookies and similar technologies to enhance your experience. We deploy the following types of cookies:

9.2 Third-Party Cookies

Spinago works with third-party providers who may set cookies on our site:

• Google Analytics: Website traffic analysis and user behavior tracking
• Payment Processors: Secure transaction processing and fraud detection
• Advertising Networks: Retargeting campaigns and conversion tracking
• Social Media Platforms: Social sharing features and analytics

9.3 Managing Cookies

You can control cookie settings through:

• Cookie Consent Banner: Adjust preferences when first visiting Spinago
• Browser Settings: Block or delete cookies via your browser preferences (note: this may affect site functionality)
• Opt-Out Tools: Use industry opt-out mechanisms like the Digital Advertising Alliance

9.4 Other Tracking Technologies

• Web Beacons: Small transparent images in emails to track open rates and link clicks
• Local Storage: HTML5 local storage for game preferences and session data
• Device Fingerprinting: Collecting device characteristics for fraud prevention and security

10. Children's Privacy

Spinago Casino is strictly prohibited for individuals under 18 years of age. We do not knowingly collect personal information from minors.

10.1 Age Verification

All users must verify they are at least 18 years old (or the legal gambling age in their jurisdiction) during registration. Spinago employs multiple verification methods:

• Date of birth declaration during Spinago account creation
• Government-issued ID verification
• Third-party age verification services
• Credit check databases (where applicable)

10.2 Parental Controls

We encourage parents and guardians to:

• Monitor children's internet usage
• Install parental control software to block gambling sites
• Report suspected underage gambling to Spinago immediately

10.3 Underage Account Discovery

If Spinago becomes aware that a user is under 18:

• The account will be immediately suspended and permanently closed
• All winnings will be forfeited
• Deposits will be returned to the payment method used (after deducting processing fees)
• Information will be reported to relevant authorities as required by law

If you believe a minor has accessed Spinago Casino, contact us immediately at the details provided in Section 14.

11. Marketing and Communications

11.1 Promotional Communications

With your consent, Spinago may send promotional materials via:

• Email (newsletters, bonus offers, tournament announcements)
• SMS/text messages (time-sensitive promotions)
• Push notifications (if enabled on your device)
• In-account messages via the Spinago login portal

11.2 Opt-Out Options

You can unsubscribe from marketing communications at any time:

• Click "Unsubscribe" links in promotional emails
• Adjust notification preferences in your Spinago account settings
• Reply "STOP" to SMS messages
• Contact customer support to update preferences

Note: Opting out of marketing does not affect transactional emails (deposit confirmations, withdrawal notifications, security alerts) or legal communications.

11.3 Personalized Marketing

Spinago may use your gaming history and preferences to tailor promotional content. This includes:

• Recommending games based on past play
• Offering bonuses aligned with your deposit patterns
• Inviting you to tournaments matching your skill level

You can opt out of personalized marketing via account settings while still receiving generic promotions.

12. Third-Party Links and Services

Spinago Casino may contain links to third-party websites, applications, or services (e.g., payment processors, affiliate sites, social media platforms). This Privacy Policy does not apply to third-party sites.

12.1 External Links

• Spinago is not responsible for the privacy practices of external websites
• We recommend reviewing the privacy policies of any third-party sites you visit
• Links to external sites do not constitute endorsement by Spinago

12.2 Payment Processors

When you make deposits or withdrawals, you interact directly with third-party payment providers (e.g., Visa, Mastercard, e-wallet services, cryptocurrency exchanges). These providers have their own privacy policies governing how they handle your financial information. Spinago does not store full credit card numbers; only tokenized references provided by payment processors.

12.3 Social Media Integration

If you connect your Spinago account to social media platforms or use social sharing features:

• The social media platform may collect information about your Spinago activity
• Your social media profile information may be shared with Spinago (with your consent)
• Consult the privacy policies of Facebook, Twitter, Instagram, or other platforms for details

13. Changes to This Privacy Policy

Spinago Casino reserves the right to update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or business operations.

13.1 Notification of Changes

• Material Changes: We will notify you via email or prominent notice on the Spinago website at least 30 days before changes take effect
• Non-Material Changes: Updates will be posted on this page with a revised "Last Updated" date

13.2 Your Acceptance

Continued use of Spinago Australia services after policy changes constitutes acceptance of the updated terms. If you disagree with changes, you must close your account before the effective date.

13.3 Policy Version History

Previous versions of this Privacy Policy are archived and available upon request to our Data Protection Officer.

14. Contact Information

15. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of Australia. Any disputes arising from this policy or Spinago Casino's data processing practices shall be subject to the exclusive jurisdiction of Australian courts.

15.1 Applicable Legislation

Spinago complies with the following Australian privacy laws:

• Privacy Act 1988 (Cth): Including the Australian Privacy Principles (APPs)
• Spam Act 2003: Governing commercial electronic messages
• Interactive Gambling Act 2001: Regulating online gambling services
• Anti-Money Laundering and Counter-Terrorism Financing Act 2006: AML/CTF obligations

15.2 Dispute Resolution

In case of privacy-related disputes:

1. Contact Spinago's Data Protection Officer to resolve the issue informally
2. If unresolved, escalate to Spinago's internal complaints process
3. Lodge a complaint with the OAIC if internal resolution fails
4. Pursue legal remedies through Australian courts as a last resort