spintim Privacy Policy

1. Introduction

spintim ("spintim," "we," "us," "our") operates the online casino and sports betting platform accessible at spintim.org. We understand that your personal data is important to you, and we take our responsibility to protect it seriously. This Privacy Policy applies to all personal data collected through the spintim website, mobile interface, customer support channels, and any other spintim service.

This Privacy Policy is intended to comply with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its implementing rules and regulations, as well as applicable PAGCOR data handling requirements. We encourage you to read this document carefully and contact us if you have any questions.

2. Data Controller

For the purposes of applicable data protection law, spintim is the data controller responsible for your personal data collected through the spintim platform. As data controller, spintim determines the purposes and means of processing your personal data.

If you have any questions about how spintim handles your personal data, or if you wish to exercise any of your data rights, you may contact our Data Protection Officer (DPO) via the contact details provided in Section 15 of this Privacy Policy.

3. Data We Collect

spintim collects the following categories of personal data from players and platform users:

Category	Examples	Purpose
Identity Data	Full name, date of birth, nationality, government-issued ID number	Account registration, KYC verification, age verification
Contact Data	Email address, mobile number, residential address	Account communication, support, regulatory compliance
Financial Data	GCash number, bank account details, transaction history, deposit and withdrawal records	Payment processing, fraud prevention, AML compliance
Technical Data	IP address, device type, browser type, operating system, session data	Platform security, fraud detection, service improvement
Usage Data	Games played, bets placed, session duration, login history, bonus usage	Responsible gaming monitoring, personalization, analytics
Communications Data	Live chat transcripts, support emails, feedback submissions	Customer support, quality assurance, dispute resolution

spintim does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required for responsible gaming assessments or regulatory compliance.

4. How We Collect Data

spintim collects personal data through the following means:

• Direct interactions: Data you provide when registering a spintim account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Data collected automatically when you access the spintim platform, including cookies, web beacons, log files, and similar tracking technologies that record your device information, IP address, and browsing behavior on the spintim site.
• Third-party sources: Data received from payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), identity verification providers, fraud prevention services, and regulatory databases where necessary to verify your identity or comply with anti-money laundering obligations.
• Publicly available sources: In limited circumstances, spintim may collect data from publicly available sources for fraud prevention or regulatory compliance purposes.

5. How We Use Your Data

spintim uses your personal data for the following purposes:

• To create, manage, and maintain your spintim player account.
• To verify your identity and age (21 years and above) in compliance with PAGCOR guidelines and Philippine law.
• To process deposits, withdrawals, and other financial transactions through your chosen payment method.
• To provide customer support and respond to your queries, complaints, and requests.
• To detect, investigate, and prevent fraud, money laundering, and other illegal or prohibited activities on the spintim platform.
• To monitor your gaming activity for responsible gaming purposes, including identifying signs of problem gambling and applying any self-imposed limits or exclusions.
• To send you account-related communications, including transaction confirmations, security alerts, and important policy updates.
• To send you promotional communications and personalized offers, where you have consented to receive such communications.
• To improve the spintim platform, analyze usage patterns, and develop new features and services.
• To comply with applicable legal and regulatory obligations, including reporting requirements under Philippine law and PAGCOR regulations.

6. Legal Basis for Processing

spintim processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you, including operating your spintim account, processing transactions, and providing gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including KYC requirements, anti-money laundering obligations, and PAGCOR reporting requirements.
• Legitimate interests: Processing necessary for spintim's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, and informed consent, such as for marketing communications. You may withdraw your consent at any time by contacting spintim support.

7. Sharing Your Data

spintim does not sell, rent, or trade your personal data to third-party marketers. We may share your personal data with the following categories of recipients only where necessary and in accordance with applicable law:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and other payment service providers, solely for the purpose of processing your financial transactions.
• Identity verification providers: Third-party KYC and identity verification services used to verify your identity and age in compliance with regulatory requirements.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where required by law or regulatory obligation.
• Law enforcement: Philippine law enforcement agencies where required by a valid legal order, court order, or where disclosure is necessary to prevent or investigate criminal activity.
• Technology service providers: Cloud hosting providers, cybersecurity firms, analytics platforms, and other technology vendors who process data on spintim's behalf under strict data processing agreements.
• Professional advisors: Legal counsel, auditors, and other professional advisors where necessary for the operation of spintim's business.

All third parties with whom spintim shares personal data are required to handle that data in accordance with applicable data protection law and spintim's data security standards.

8. Data Retention

spintim retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements. The following general retention periods apply:

• Account data: Retained for the duration of your active spintim account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine anti-money laundering regulations.
• KYC documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Support communications: Retained for up to three (3) years from the date of the communication, unless a longer retention period is required for dispute resolution or legal proceedings.
• Marketing consent records: Retained for the duration of your consent and for a reasonable period thereafter to demonstrate compliance.

When personal data is no longer required, spintim will securely delete or anonymize it in accordance with our data disposal procedures.

9. Cookies & Tracking Technologies

spintim uses cookies and similar tracking technologies (including web beacons, pixel tags, and local storage) to operate and improve the spintim platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the operation of the spintim platform, including maintaining your login session and remembering your preferences.
• Analytical cookies: Used to collect information about how players use the spintim platform, helping us understand usage patterns and improve our services.
• Functional cookies: Allow spintim to remember choices you make (such as language preferences) and provide enhanced, personalized features.
• Security cookies: Used to detect and prevent fraudulent activity, protect your spintim account, and maintain platform integrity.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the spintim platform. For more information on managing cookies, refer to your browser's help documentation.

10. Data Security

spintim implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the spintim platform.
• Secure, access-controlled server infrastructure with regular security audits and penetration testing.
• Role-based access controls ensuring that spintim staff can only access personal data necessary for their specific job functions.
• Regular staff training on data protection obligations and information security best practices.
• Incident response procedures to detect, report, and address any personal data breaches in accordance with applicable law.

While spintim takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, spintim will notify you and the National Privacy Commission (NPC) as required by the Data Privacy Act of 2012.

11. Your Rights

Under the Data Privacy Act of 2012 and applicable Philippine data protection law, you have the following rights in relation to your personal data held by spintim:

• Right to be informed: The right to be informed about how spintim collects and uses your personal data, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data spintim holds about you.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data spintim holds about you.
• 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 spintim's legal and regulatory retention obligations.
• Right to object: The right to object to spintim's 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 lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe spintim has not handled your personal data in accordance with applicable law.

To exercise any of these rights, please contact the spintim Data Protection Officer using the contact details in Section 15. spintim will respond to all valid requests within thirty (30) days. We may need to verify your identity before processing your request.

12. Children & Minors

The spintim platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR guidelines applicable to online casino gaming in the Philippines. spintim does not knowingly collect personal data from individuals under the age of 21.

If spintim becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the spintim platform, please contact our support team immediately.

13. International Transfers

spintim primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to and processed in countries outside the Philippines — for example, where spintim uses cloud infrastructure or technology service providers with servers located abroad.

Where personal data is transferred outside the Philippines, spintim ensures that appropriate safeguards are in place to protect your data, including contractual clauses that require the recipient to protect your personal data to a standard equivalent to that required under Philippine law. By using the spintim platform, you consent to such transfers where they are necessary for the provision of spintim's services.

14. Changes to This Policy

spintim reserves the right to update or modify this Privacy Policy at any time. Any changes will be posted on this page with an updated effective date. Where changes are material, spintim will make reasonable efforts to notify registered players via email or an in-platform notification prior to the changes taking effect.

Your continued use of the spintim platform following the posting of any changes to this Privacy Policy constitutes your acceptance of those changes. We encourage you to review this Privacy Policy periodically to stay informed about how spintim protects your personal data.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or spintim's handling of your personal data, please contact our Data Protection Officer:

Email: [email protected]

spintim's customer support team is available 24/7 to assist all Filipino players with privacy-related queries. We are committed to resolving all data protection concerns promptly and transparently.

This Privacy Policy was last updated on January 1, 2026 and is effective as of that date.