Spin77 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how Spin77 ("Spin77," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of users ("you," "Player," or "User") who access or use the Spin77 website, mobile application, and all related services (collectively, the "Platform").

Spin77 is committed to protecting the privacy and personal data of all players on our Platform. We operate in the Philippines and process personal data in accordance with applicable Philippine data protection legislation and the requirements of our gaming regulatory framework.

By registering an account on Spin77, accessing the Platform, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Spin77 Platform and contact us to close your account.

2. Personal Data We Collect

2.1 Information You Provide Directly

When you register for a Spin77 account or interact with our Platform, we collect personal data that you provide to us directly, including:

• Identity data: Full name, date of birth, gender, and nationality.
• Contact data: Email address, mobile number, and residential address (including city, province, and postal code).
• Account credentials: Username and encrypted password.
• Verification documents: Government-issued photo ID (such as a Philippine passport, driver's licence, SSS card, or UMID), proof of address, and payment method verification documents submitted as part of our KYC process.
• Financial data: Payment method details, transaction history, deposit and withdrawal records, and GCash or PayMaya account references where applicable.
• Communications data: Records of your correspondence with our customer support team, including live chat transcripts and email exchanges.

2.2 Information Collected Automatically

When you access the Spin77 Platform, we automatically collect certain technical and usage data, including:

• Device and technical data: IP address, device type, operating system, browser type and version, and unique device identifiers.
• Usage data: Pages visited, games played, betting history, session duration, click-stream data, and features accessed on the Platform.
• Location data: General geographic location derived from your IP address. We do not collect precise GPS location data unless you explicitly grant permission through the Spin77 mobile application.
• Cookie data: Information collected through cookies and similar tracking technologies as described in Section 6 of this Policy.

3. How We Use Your Personal Data

Spin77 uses the personal data we collect for the following purposes:

• Account management: To create, maintain, and manage your Spin77 player account, including processing deposits, withdrawals, and bet settlements.
• Identity verification: To verify your identity and age (21+) as required by our regulatory obligations and to prevent underage gambling.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, money laundering, account takeovers, and other illegal or prohibited activities on the Platform.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Regulatory compliance: To comply with applicable Philippine laws, gaming regulations, anti-money laundering (AML) requirements, and any lawful requests from regulatory or law enforcement authorities.
• Platform improvement: To analyse usage patterns, conduct research, and improve the features, performance, and user experience of the Spin77 Platform.
• Responsible gaming: To monitor gaming behaviour and identify players who may be at risk of problem gambling, in accordance with our Responsible Gaming Policy.
• Marketing communications: To send you promotional offers, bonuses, and updates about Spin77 where you have provided your consent to receive such communications. You may opt out at any time.

Spin77 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

4. Legal Basis for Processing

Spin77 processes your personal data on the following legal bases:

• Contractual necessity: Processing that is necessary to perform our contract with you — that is, to operate your Spin77 account and provide the services you have requested.
• Legal obligation: Processing that is required to comply with applicable laws and regulations, including KYC, AML, and gaming regulatory requirements.
• Legitimate interests: Processing that is necessary for our legitimate business interests, such as fraud prevention, platform security, and improving our services, provided that such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent, such as the sending of direct marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Sharing Your Personal Data

Spin77 does not sell, rent, or trade your personal data to third parties. We may, however, share your personal data with the following categories of recipients where necessary and in accordance with this Policy:

5.1 Service Providers

We engage trusted third-party service providers to assist us in operating the Spin77 Platform, including payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank gateway providers), identity verification services, cloud hosting providers, customer support platforms, and analytics providers. These service providers are contractually obligated to process your data only on our instructions and to maintain appropriate security measures.

5.2 Regulatory and Law Enforcement Authorities

Spin77 may disclose your personal data to relevant Philippine regulatory bodies, law enforcement agencies, or other competent authorities where required to do so by law, court order, or regulatory direction, or where we reasonably believe disclosure is necessary to prevent fraud, money laundering, or other illegal activity.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of Spin77's business, your personal data may be transferred to the relevant successor entity. We will notify you of any such transfer and the privacy practices of the successor entity prior to your data being transferred.

6. Cookies & Tracking Technologies

Spin77 uses cookies and similar tracking technologies (such as web beacons and pixel tags) to enhance your experience on the Platform, analyse usage patterns, and support our security and fraud prevention measures.

6.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that help protect your account. These cannot be disabled.
• Functional cookies: Remember your preferences and settings, such as your preferred language and display options, to provide a more personalised experience on Spin77.
• Analytics cookies: Help us understand how players use the Spin77 Platform by collecting aggregated, anonymised data about page visits, session duration, and feature usage. This data is used solely to improve the Platform.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and other security threats on the Platform.

6.2 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Spin77 Platform. Strictly necessary cookies cannot be disabled as they are essential for the Platform to operate.

7. Data Retention

Spin77 retains your personal data for as long as your account remains active and for such additional period as is necessary to comply with our legal and regulatory obligations. Specifically:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with applicable AML and gaming regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• KYC documents: Retained for the period required by applicable Philippine regulations, typically five (5) years from the date of submission or account closure, whichever is later.
• Customer support records: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required for dispute resolution or regulatory purposes.
• Marketing data: Retained until you withdraw your consent to receive marketing communications or request deletion, subject to any overriding legal obligations.

Upon expiry of the applicable retention period, Spin77 will securely delete or anonymise your personal data in accordance with our internal data disposal procedures.

8. Data Security

Spin77 takes the security of your personal data seriously. We implement a range of technical and organisational security measures to protect your data against unauthorised access, disclosure, alteration, or destruction, including:

• Encryption of data in transit using TLS (Transport Layer Security) protocols.
• Encryption of sensitive data at rest, including payment information and identity documents.
• Strict access controls ensuring that only authorised Spin77 personnel can access personal data, on a need-to-know basis.
• Regular security assessments and penetration testing of the Platform.
• Two-factor authentication options for player accounts.
• Continuous monitoring for suspicious activity and potential security incidents.

While Spin77 takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, Spin77 will notify you and the relevant authorities as required by applicable law.

9. Your Rights

As a data subject, you have the following rights in relation to the personal data that Spin77 holds about you:

• Right of access: You have the right to request a copy of the personal data that Spin77 holds about you, along with information about how it is being used.
• Right to rectification: You have the right to request that Spin77 correct any inaccurate or incomplete personal data held about you.
• Right to erasure: You have the right to request that Spin77 delete your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal and regulatory retention obligations.
• Right to restriction: You have the right to request that Spin77 restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format where processing is based on your consent or a contract.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on our legitimate interests, subject to our demonstrating compelling legitimate grounds.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact the Spin77 support team using the contact details provided in Section 12 of this Policy. We will respond to all valid requests within a reasonable timeframe and in accordance with applicable law. Please note that certain rights may be limited where Spin77 is required to retain or process your data to comply with legal or regulatory obligations.

10. Children and Minors

The Spin77 Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. Spin77 does not knowingly collect personal data from any person under the age of 21.

If Spin77 becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Spin77 Platform, please contact us immediately using the details in Section 12.

11. Changes to This Privacy Policy

Spin77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. The date of the most recent revision is indicated at the top of this page.

Where changes to this Policy are material, Spin77 will endeavour to provide reasonable advance notice to registered players via email or a prominent notice on the Platform. Your continued use of the Spin77 Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how Spin77 protects your personal data.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way Spin77 handles your personal data, please contact our support team. We are available 24/7 and will be happy to assist you.

For information about your rights as a player, please also refer to our Terms & Conditions. For responsible gaming support and self-exclusion tools, visit our Responsible Gaming page. General questions are answered on our FAQ page.