PRIVACY POLICY

Last updated in November 2024

1. Introduction

Spinoloco.com is committed to protecting your personal information. This Privacy Policy (the “Policy”) provides important information about how Spinoloco.com (“We”, “Us”, “Our”, “Website”) handles the collection, use and protection of personal information it received through its website, platform and upon providing its services.

This Policy is an integral part of Spinoloco's Terms and Conditions. Therefore, when a said person (hereinafter “You”, “Your”, “Yourself” or “User”, “Player”, “Customer” interchangeably) access or use the Website, you automatically agree to our collection, use and disclosure of your information in accordance with this Policy.

The Website is owned and operated by Medial N.V., a company registered under Curaçao Law, licensed and regulated by the Curacao Gaming Control Board (GCB) with License Number: OGL/2023/115/0092, and registered address at Zuikertuintjeweg Z/N, Curacao. The Website is owned and operated by Medial N.V., a company registered under Curaçao Law, licensed and regulated by the Curacao Gaming Control Board (GCB) with License Number: OGL/2023/115/0092, and registered address at Zuikertuintjeweg Z/N, Curacao.

We are committed to protecting your privacy and handling your data safe and confidential. This Policy describes what types of personal data We collect, how We use them, when and with whom We share it and how we keep it safe. It also specifies your rights and how you may choose to exercise them. . We are committed to protecting your privacy and handling your data safe and confidential. This Policy describes what types of personal data We collect, how We use them, when and with whom We share it and how we keep it safe. It also specifies your rights and how you may choose to exercise them. .

For the purposes of this Policy, personal data and/or personal information shall mean any information relating to a user, client, potential client, partner or third-party which identifies or may identify them, and which includes, for example name, location, identification number and email address. For the purposes of this Policy, personal data and/or personal information shall mean any information relating to a user, client, potential client, partner or third-party which identifies or may identify them, and which includes, for example name, location, identification number and email address.

2. Personal Information we collect

We collect basic information that can be used to identify an individual, including but not limited to first and last name, date of birth, address or other physical address, email address, telephone number or other relevant information ("Personal Information"). You may be asked to provide Personal Information when you use our Website, register an account and/or use our services. The Personal Information we collect may also include information such as transaction history, Website usage preferences and comments about the Services. The information is essential for the provision and quality of our services,  and is stored by us on our secure servers based abroad. When you interact with the Services, our servers keep an activity log unique to you that collects certain administrative and traffic information, including: originating IP address, time of access, date of access, web page(s) visited, language used, software crash reports and type of browser used. Communications between you and Spinoloco are recorded and can be used by both parties in the event of a dispute. We do not collect personal information about you without your knowledge.

3. How we use the personal information we collect and who receives it

We may automatically collect certain data, as mentioned above, and receive Personal Information about you when you provide it through the services or other communications and interactions on the Spinoloco Website. We may also receive Personal Information from third-party entities such as online merchants and external service providers, and from customer lists lawfully acquired from them, as part of our regulatory requirements. In addition, we may partner with third parties to provide technical support, process your online transactions and maintain your account. We will have access to all the information you provide to these third-party vendors, service providers and e-commerce services, and we will use the Personal Information described in this Privacy Policy. This information will only be disclosed to third parties in accordance with this Privacy Policy. We take steps to ensure that our agreements with third party service providers and online merchants protect your privacy. We may automatically collect certain data, as mentioned above, and receive Personal Information about you when you provide it through the services or other communications and interactions on the Spinoloco Website. We may also receive Personal Information from third-party entities such as online merchants and external service providers, and from customer lists lawfully acquired from them, as part of our regulatory requirements. In addition, we may partner with third parties to provide technical support, process your online transactions and maintain your account. We will have access to all the information you provide to these third-party vendors, service providers and e-commerce services, and we will use the Personal Information described in this Privacy Policy. This information will only be disclosed to third parties in accordance with this Privacy Policy. We take steps to ensure that our agreements with third party service providers and online merchants protect your privacy.

It must be noted that we may disclose data about you for any of the reasons set out hereinabove or if we are legally required to do so, or if we are authorised under our contractual and statutory obligations or if you have given your consent. It must be noted that we may disclose data about you for any of the reasons set out hereinabove or if we are legally required to do so, or if we are authorised under our contractual and statutory obligations or if you have given your consent.

Under the circumstances referred to above, recipients of your personal data may be: Under the circumstances referred to above, recipients of your personal data may be:

• Supervisory and other regulatory and public authorities, notary offices, tax authorities, criminal prosecution authorities as much as a statutory obligation exists; Supervisory and other regulatory and public authorities, notary offices, tax authorities, criminal prosecution authorities as much as a statutory obligation exists;
• Government bodies and law enforcement agencies where required by law and in response to other legal and regulatory requests; Government bodies and law enforcement agencies where required by law and in response to other legal and regulatory requests;
• External legal consultants authorised by the us; External legal consultants authorised by the us;
• Marketing and advertising agencies; Marketing and advertising agencies;
• Fraud prevention agencies; Fraud prevention agencies;
• File storage companies, archiving and/or records management companies, cloud storage companies; File storage companies, archiving and/or records management companies, cloud storage companies;
• External authorised processors for processing client data; External authorised processors for processing client data;
• Anyone authorized by you; Anyone authorized by you;

We endeavor to disclose to any third parties only the minimum personal data that is required to perform their contractual obligations to us. Our third-party service providers are not permitted to share or use personal data we make available to them for any other purpose than to provide services to us. Our website may have links to external third-party websites. Please note, however, that third party websites are not covered by this privacy notice and those sites are not subject to our privacy standards and procedures.  We endeavor to disclose to any third parties only the minimum personal data that is required to perform their contractual obligations to us. Our third-party service providers are not permitted to share or use personal data we make available to them for any other purpose than to provide services to us. Our website may have links to external third-party websites. Please note, however, that third party websites are not covered by this privacy notice and those sites are not subject to our privacy standards and procedures.

We use the Personal Information we collect from you to provide our Services, provide customer support, perform security and identity checks, process any of your online transactions, allow your participation in third-party promotions, fulfill certain business requirements and for any other purpose related to the operation of the Services. As such, we may share your Personal Information with our carefully selected partners (including any other parties that have data sharing agreements with them). Your Personal Information may also be used by Us to provide you with (1) promotional offers and information regarding our products and services; and 2) promotional offers and information relating to our partners' products and services, in order to extend the range of products provided and improve our customer service. You may opt out of receiving promotional information by contacting us by email support@spinoloco.com or Live Chat.

We respect the national and EU legal regulations in force, in particular National Law no. 58/2019 (GDPR - General Data Protection Regulation) which ensures the implementation of EU Regulation 2016/679 on the protection of individuals with regard to the processing of Personal Information and on the free movement of such data.  We respect the national and EU legal regulations in force, in particular National Law no. 58/2019 (GDPR - General Data Protection Regulation) which ensures the implementation of EU Regulation 2016/679 on the protection of individuals with regard to the processing of Personal Information and on the free movement of such data.

5. Consent to the use of electronic service providers

To play on our Website, you will need to send and receive money from us. We may use third-party electronic payment systems to process these financial transactions. By accepting this Privacy Policy, you expressly consent to your Personal Information being required for the processing of transactions, including, where necessary, the transfer of information outside your country. We take steps to ensure that our agreements with payment systems protect your privacy. To play on our Website, you will need to send and receive money from us. We may use third-party electronic payment systems to process these financial transactions. By accepting this Privacy Policy, you expressly consent to your Personal Information being required for the processing of transactions, including, where necessary, the transfer of information outside your country. We take steps to ensure that our agreements with payment systems protect your privacy.

6. Consent to Security Verifications

We reserve the right to perform a security analysis at any time to validate the registration data provided by you and to verify your use of the services and financial transactions that may constitute potential violations of our Terms and Conditions and applicable law. We reserve the right to perform a security analysis at any time to validate the registration data provided by you and to verify your use of the services and financial transactions that may constitute potential violations of our Terms and Conditions and applicable law.

By using our services and agreeing to our Terms and Conditions, you authorize us to use your Personal Information and to disclose your Personal Information to third parties for the purposes of validating the information you provide while using our services, including, where necessary, transferring information outside your country. To facilitate these security reviews, you agree to provide such information or documentation as we may request. By using our services and agreeing to our Terms and Conditions, you authorize us to use your Personal Information and to disclose your Personal Information to third parties for the purposes of validating the information you provide while using our services, including, where necessary, transferring information outside your country. To facilitate these security reviews, you agree to provide such information or documentation as we may request.

7. Your rights 

You have the following rights and protections in terms of processing the Personal Information we hold about you: You have the following rights and protections in terms of processing the Personal Information we hold about you:

1. Request access to your Personal Information: You have the right to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it. Request access to your Personal Information: You have the right to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.

1. Request rectification/correction of the Personal Information we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. We may request additional information and documentation required to validate the need for the requested change of data. Request rectification/correction of the Personal Information we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. We may request additional information and documentation required to validate the need for the requested change of data.

1. Request erasure of your personal information. You can ask us to erase your Personal Information, exercising your right “to be forgotten”, where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. However, Spinoloco is required to maintain the client’s personal data to comply with its legal and regulatory requirements, as well as in accordance with internal compliance requirements in relation to the maintenance of records. We shall preserve data for at least five years following the termination of the client relationship, unless other terms for the preservation of data or documents are prescribed by law. Request erasure of your personal information. You can ask us to erase your Personal Information, exercising your right “to be forgotten”, where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. However, Spinoloco is required to maintain the client’s personal data to comply with its legal and regulatory requirements, as well as in accordance with internal compliance requirements in relation to the maintenance of records. We shall preserve data for at least five years following the termination of the client relationship, unless other terms for the preservation of data or documents are prescribed by law.
2. You have the right to object to the definition and creation of your profile based on automation systems and executed by human force. This profiling is intended to allow you to register on the Website, improve your experience, personalize it and ensure that we comply with legal obligations regarding the prevention of fraud and money laundering, and combating the financing of terrorist activities. You have the right to object to the definition and creation of your profile based on automation systems and executed by human force. This profiling is intended to allow you to register on the Website, improve your experience, personalize it and ensure that we comply with legal obligations regarding the prevention of fraud and money laundering, and combating the financing of terrorist activities.

1. You have the right to receive your Personal Information in a structured and legible format, as well as the right to transmit it to another party. This right applies only to the processing of Personal Information carried out on the basis of your consent or when the processing is carried out by automated means. You have the right to receive your Personal Information in a structured and legible format, as well as the right to transmit it to another party. This right applies only to the processing of Personal Information carried out on the basis of your consent or when the processing is carried out by automated means.

1. You have the right to object to the processing of your Personal Information, for your own reasons and without any obligation to disclose them. In very exceptional cases provided for in the GDPR, such as possible legal or regulatory proceedings, Spinoloco may continue to process your Personal Information for purposes other than marketing, as mentioned above. You have the right to object to the processing of your Personal Information, for your own reasons and without any obligation to disclose them. In very exceptional cases provided for in the GDPR, such as possible legal or regulatory proceedings, Spinoloco may continue to process your Personal Information for purposes other than marketing, as mentioned above.

To exercise any of the rights covered, you can contact us by email at support@spinoloco.com, attaching a copy of your identification document in order to verify your identity.

8. Exceptions

We may disclose your Personal Information if required to do so by law, or if we believe in good faith that such action is necessary to (1) comply with any legal process served on us, any of our Websites or the services or in circumstances where we are subject to a substantially similar legal obligation; (2) protect and defend our rights or property; or (3) act to protect the personal safety of users of the services or the public. If, in our sole determination, you are found to have cheated or attempted to defraud us or any other user of the services in any way, including but not limited to game manipulation or fraudulent payment, such as the use of stolen credit cards, or any other fraudulent activity (including any "chargeback" or other reversal of a payment) or prohibited transaction (including money laundering), we reserve the right to share this information, as well as your identity, with the relevant Authorities. (4) For the purposes of research into gambling addiction, data may be anonymized and passed on to the relevant institutions for scientific analysis. We may disclose your Personal Information if required to do so by law, or if we believe in good faith that such action is necessary to (1) comply with any legal process served on us, any of our Websites or the services or in circumstances where we are subject to a substantially similar legal obligation; (2) protect and defend our rights or property; or (3) act to protect the personal safety of users of the services or the public. If, in our sole determination, you are found to have cheated or attempted to defraud us or any other user of the services in any way, including but not limited to game manipulation or fraudulent payment, such as the use of stolen credit cards, or any other fraudulent activity (including any "chargeback" or other reversal of a payment) or prohibited transaction (including money laundering), we reserve the right to share this information, as well as your identity, with the relevant Authorities. (4) For the purposes of research into gambling addiction, data may be anonymized and passed on to the relevant institutions for scientific analysis.

9. Cookies

We use cookies to store and collect information about your use of our Website. Cookies are small text files stored by the browser on your equipment’s hard drive. They send information stored on them back to our web server when you access our Website. These cookies enable us to put in place personal settings and load your personal preferences to improve your experience. To find out more about how we use cookies please see Our Cookie Policy available. We use cookies to store and collect information about your use of our Website. Cookies are small text files stored by the browser on your equipment’s hard drive. They send information stored on them back to our web server when you access our Website. These cookies enable us to put in place personal settings and load your personal preferences to improve your experience. To find out more about how we use cookies please see Our Cookie Policy available.

on our website. on our website.

1. Information stored on your device: When you access our services, we may store information on your device. This information is called cookies, which are small text files stored on your device when you visit online pages and which record your preferences. We also use Local Sharing Objects or "flash cookies". Flash cookies are similar to browser cookies. Neither cookies nor flash cookies can be used to access or use other information on your computer. We only use these methods to record your use of our services. Cookies help us monitor traffic on the Website, improve our services and make them simpler and/or more relevant for your use. We use flash cookies and third-party cookies to help us show you more relevant and desirable advertisements.  Information stored on your device: When you access our services, we may store information on your device. This information is called cookies, which are small text files stored on your device when you visit online pages and which record your preferences. We also use Local Sharing Objects or "flash cookies". Flash cookies are similar to browser cookies. Neither cookies nor flash cookies can be used to access or use other information on your computer. We only use these methods to record your use of our services. Cookies help us monitor traffic on the Website, improve our services and make them simpler and/or more relevant for your use. We use flash cookies and third-party cookies to help us show you more relevant and desirable advertisements.
2. Strictly necessary cookies are essential to allow you to browse the Website and use its features, such as accessing secure areas of the Website or making financial transactions. Without these cookies, it would not be possible for our Website to work efficiently. Strictly necessary cookies are essential to allow you to browse the Website and use its features, such as accessing secure areas of the Website or making financial transactions. Without these cookies, it would not be possible for our Website to work efficiently.
3. During the registration process. These cookies store information collected during your registration and allow us to recognize you as a customer and provide you with the services you need. We may also use this data to better understand your interests while you are online and to improve your visits to our platform. During the registration process. These cookies store information collected during your registration and allow us to recognize you as a customer and provide you with the services you need. We may also use this data to better understand your interests while you are online and to improve your visits to our platform.
4. For visitors to our Website, we use cookies to collect information. Our servers use three different types of cookies:  For visitors to our Website, we use cookies to collect information. Our servers use three different types of cookies:
5. Session-based cookies: this type of cookie is only assigned to your computer during your visit to our Website. A session-based cookie helps you navigate our website more quickly and, if you are a registered customer, allows us to provide you with information that is more relevant to you. This cookie expires automatically when you close your browser. Session-based cookies: this type of cookie is only assigned to your computer during your visit to our Website. A session-based cookie helps you navigate our website more quickly and, if you are a registered customer, allows us to provide you with information that is more relevant to you. This cookie expires automatically when you close your browser.
6. Persistent cookies: this type of cookie will remain on your computer for a period defined for each cookie. Flash cookies are also persistent. Persistent cookies: this type of cookie will remain on your computer for a period defined for each cookie. Flash cookies are also persistent.
7. Analytical cookies: this type of cookie allows us to recognize and count the number of visitors to our website, and understand how visitors use our services. This helps us improve the functioning of our website, for example, by ensuring that the user can easily find what they are looking for. You have the option of accepting or rejecting cookies. Most web browsers automatically accept cookies, but if you prefer, you can modify your browser settings to prevent them. The Help menu in the menu bar of most browsers tells you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies completely. Analytical cookies: this type of cookie allows us to recognize and count the number of visitors to our website, and understand how visitors use our services. This helps us improve the functioning of our website, for example, by ensuring that the user can easily find what they are looking for. You have the option of accepting or rejecting cookies. Most web browsers automatically accept cookies, but if you prefer, you can modify your browser settings to prevent them. The Help menu in the menu bar of most browsers tells you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies completely.
8. Flash cookies. You can modify your Flash Player settings to prevent the use of "flash cookies". The Settings Manager of your Flash Player allows you to manage your preferences. To disallow flash cookies from all third-party content, go to the Settings Manager's "Global Storage Settings" panel, uncheck the "Allow third-party flash content to store information on your computer" box, and close the Settings Manager. Alternatively, you can also adjust the settings for specific websites you visit via the "Website Storage Settings" panel, which is also in the Settings Manager. If you are using an older version of Flash Player or an older browser, the Settings Manager may not be available. We recommend that you make sure you update your Flash Player and browser to the latest versions available. If you choose to refuse cookies, you may not be able to enjoy all the interactive features of our Website. Flash cookies. You can modify your Flash Player settings to prevent the use of "flash cookies". The Settings Manager of your Flash Player allows you to manage your preferences. To disallow flash cookies from all third-party content, go to the Settings Manager's "Global Storage Settings" panel, uncheck the "Allow third-party flash content to store information on your computer" box, and close the Settings Manager. Alternatively, you can also adjust the settings for specific websites you visit via the "Website Storage Settings" panel, which is also in the Settings Manager. If you are using an older version of Flash Player or an older browser, the Settings Manager may not be available. We recommend that you make sure you update your Flash Player and browser to the latest versions available. If you choose to refuse cookies, you may not be able to enjoy all the interactive features of our Website.

10. Security

We understand the importance of security and know the procedures required to protect information. We understand the importance of security and know the procedures required to protect information.

We store all Personal Information we receive directly from you in an encrypted, password-protected database that resides on our secure network, backed by state-of-the-art firewall software that is permanently active (our Services support SSL Version 3 with 128-bit encryption). We also take steps to ensure that our subsidiaries, agents, affiliates and suppliers adopt appropriate security measures. We store all Personal Information we receive directly from you in an encrypted, password-protected database that resides on our secure network, backed by state-of-the-art firewall software that is permanently active (our Services support SSL Version 3 with 128-bit encryption). We also take steps to ensure that our subsidiaries, agents, affiliates and suppliers adopt appropriate security measures.

11. Links of other websites

Our Website may contain links to external websites that are outside our sphere and are not covered by this Privacy Policy. As these websites are independently owned and operated by other persons or entities, these operators may collect information about you and use it in accordance with their privacy policy, which may differ from ours if you access them. Our terms of use and our Privacy Policy apply only to information collected by us in accordance with this Policy. Our Website may contain links to external websites that are outside our sphere and are not covered by this Privacy Policy. As these websites are independently owned and operated by other persons or entities, these operators may collect information about you and use it in accordance with their privacy policy, which may differ from ours if you access them. Our terms of use and our Privacy Policy apply only to information collected by us in accordance with this Policy.

12. Changes to our Privacy Policy

Your use of our services constitutes your agreement to our Privacy Policy. This is our full and exclusive Privacy Policy and supersedes any previous version. This Privacy Policy should be read in conjunction with our Terms and Conditions and any additional applicable terms posted on our platforms. The Company reserves the right to modify or amend this Privacy unilaterally at any time in accordance with this provision. If any changes are made to this Policy, we shall notify you accordingly. The revision date shown at the end of this page will also be amended. We do, however, encourage you to review this privacy statement occasionally so as to always be informed about how we are processing and protecting your personal information. Your continued use of our services following any changes to this Privacy Policy constitutes your acceptance of the changes. We recommend that you review this Privacy Policy regularly.  Your use of our services constitutes your agreement to our Privacy Policy. This is our full and exclusive Privacy Policy and supersedes any previous version. This Privacy Policy should be read in conjunction with our Terms and Conditions and any additional applicable terms posted on our platforms. The Company reserves the right to modify or amend this Privacy unilaterally at any time in accordance with this provision. If any changes are made to this Policy, we shall notify you accordingly. The revision date shown at the end of this page will also be amended. We do, however, encourage you to review this privacy statement occasionally so as to always be informed about how we are processing and protecting your personal information. Your continued use of our services following any changes to this Privacy Policy constitutes your acceptance of the changes. We recommend that you review this Privacy Policy regularly.

13. Minors

Spinoloco is not available for users under the age of 18 (or the age requiring legal consent of the jurisdiction the user is located in) (a “Minor”). We do not knowingly collect personal information from or about Minors. If you are a Minor, you should not download or use any of our services nor provide any personal information to us. If we become aware that a Minor has shared any information with us, we will delete such information. If you have any reason to believe that a minor has shared any information with us, please contact us at support@spinoloco.com.

14. Your right to lodge a complaint

In addition, pursuant to Article 77 of the GDPR, you have the right to lodge a complaint regarding the processing of your data with the relevant supervisory authority. If you have exercised any or all of your data protection rights and still feel that your concerns about how we use your personal data have not been adequately addressed by us, you have the right to complain by sending an email to support@spinoloco.com.  You also have the right to file a complaint to the Office of the Commissioner for Personal Data Protection. Instructions as to how to submit a complaint can be found in their website: www.dataprotection.gov.cy. Alternatively, you also have the right to lodge a complaint with the data protection authority of your country of residence.

15. Other related information

We use appropriate technical, organizational, and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration and destruction. Unfortunately, no company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.  We use appropriate technical, organizational, and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration and destruction. Unfortunately, no company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

Among other practices, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.  Among other practices, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

Transmission of information via regular email exchange is not always completely secure. However we exercise all possible actions to protect clients’ personal data, yet it cannot guarantee the security of client data that is transmitted via email; any transmission is at the clients’ own risk. Once we have received the client information it will use procedures and security features to prevent unauthorized access. When you email us or using the Live Chat feature, you may be requested to provide some additional personal data, like your name or email address. Such data will be used to respond to your enquiry and verify your identity. Emails are stored on our standard internal contact systems which are secure and cannot be accessed by unauthorized external parties. Transmission of information via regular email exchange is not always completely secure. However we exercise all possible actions to protect clients’ personal data, yet it cannot guarantee the security of client data that is transmitted via email; any transmission is at the clients’ own risk. Once we have received the client information it will use procedures and security features to prevent unauthorized access. When you email us or using the Live Chat feature, you may be requested to provide some additional personal data, like your name or email address. Such data will be used to respond to your enquiry and verify your identity. Emails are stored on our standard internal contact systems which are secure and cannot be accessed by unauthorized external parties.