Spinly Privacy Policy

This Privacy Policy provides an explanation of why Player information is collected, how it is collected, and how Spinly keeps it secure. Spinly is committed to respecting and protecting Player privacy, for the importance of maintaining the trust and confidence of Players. Spinly is committed to complying with obligations under all applicable global data privacy laws, including the General Data Protection Regulation ("GDPR"), the California Consumer Privacy Act ("CCPA"), and the Virginia Consumer Data Protection Act ("VCDPA").

This Privacy Policy governs the way Spinly collects, uses, maintains, and discloses the information collected through https://www.Spinly.com and any subdomains, subpages, successor sites or any application accessible via our website (the “Spinly Platform”). This Privacy Policy applies to the Spinly Platform and all products and services offered through it.

1. The Spinly Privacy Policy is Subject to Change

1. This Policy may be updated from time to time as necessary to safeguard Player data collection. When this happens, Players will be notified of any material change affecting them, and when required by law, will need Players’ consent. Notice may be provided to Players by posting such changes on the Platform, or by other means that comply with applicable laws.

2. Players are encouraged to regularly check this page for any changes or revisions to the Privacy Policy and to stay accurately up to date with how Spinly helps protect the personal information it collects.

3. Any changes made to this Privacy Policy will become effective when the updated policy is posted on the Platform.

4. This Privacy Policy is in effect from the last date at the top of the document. Any updated version will replace and supersede any Privacy Policy that has previously been in effect.

    

2. Collected Information

1. The data controller responsible for processing data collected through Players’ use of the Spinly Platform (including any data Players may provide through the Platform when they purchase a product or service or take part in a promotion or competition) is Spinly. (the "Data Controller" or “Spinly”).

2. This Privacy Policy is incorporated into and part of the Spinly [Terms and Conditions]. The Definitions of those terms set forth in the Terms and Conditions apply equally here and carry the same meaning.

3. Spinly collects two general forms of information about its Players: personal information and anonymous information. Personal information consists of any information about the Player, accurate or not, where their identity is discernable, or can reasonably be discerned. Anonymous information does not directly or indirectly identify an individual and cannot be reasonably used to identify an individual. In situations where anonymous information is directly or indirectly associated with personal information, the resulting information is treated as personal information. Spinly may use personal and anonymous information to create a third type of information known as aggregate information. Aggregate does not include the ability to identify an individual Player from this category.

4. Spinly collects:
   • Players’ personal contact details including their first and last name, email, address, residential address and phone numbers;
   • Personal information including Players’ age, gender, image, account login (including username, password and any pictures used with their profile);
   • Information sent using email, post or other methods of communication;

   • Any information Spinly obtains from a third party (such as Meta) about interest in its services;

   • Information such as Players’ postal address, phone number, payment information (banking and financial details, account statements, and credit card details) or any information you provide when making a purchase, requesting a redemption, payment or any use otherwise;

   • Where permitted by law, Spinly collects Players’ location information provided by a mobile or other device used to access the Platform, or associated with Players’ IP address;

   • Any activity while using the Platform (includes duration of Players’ visit on the Platform, the content viewed, how often Players use the services, Players’ interaction with the Platform, device type, preferences and interaction with the Content on our website, your browser type and IP address);

   • Government issued identifiers such as a driver's license, social security number, or passport (when Spinly is required to have this information for tax or other legal reasons);
   • Spinly may collect Players’ geolocation, financial information, biometric data, and driver’s licenses collected for necessity of legal and regulatory compliance.
5. Spinly uses identifiers such as cookies and similar available technology, to help make Players’ experience with the Platform as simple and useful as possible.

6. In order to enhance Players’ experience on the Platform, Spinly uses technology such as small files, placed on Player devices when they visit the Platform. This allows Spinly to record pieces of information when Players visit or interact with the Platform. The information collected may include Player browser type, device type, operating system, geolocation, the time, referring URLs and other information Spinly deems necessary to collect. The data collected provides information about Player engagement with the page, including the content and how long the Player stayed on that page. This information is usually general and non-identifying; however, Spinly will treat it as personal Information and associate it with the Player as an identifiable person.

7. Examples of the types of technology used:

   • Cookies: store Player preferences in small text files located in their device’s browsers. Browsers may allow the Player to block or delete cookies, but this may interfere with the Platform’s ability to work correctly.

   • APIs: allow different kinds of software programs to communicate with one another. They provide better experiences for both Players and programmers.

   • Mobile device identifiers: are used for identifying Player devices for internet-based advertising. The advertising identifier associated with a Player’s device (such as Google Advertising ID and Apple IDFA) may be shared by us to advertisers.

   • Pixel tags (web beacons): are codes embedded in the Platform that collect information for Spinly to record information such as whether a Player clicked on a particular advertisement. Spinly may also use the web beacons in emails to determine whether they have been opened, forwarded, or acted on in any way.

   • Event tagging: allows Spinly to track application installs, purchases, and other events that occur on the Platform. Spinly uses this data to measure ad performance, build audiences used for ad targeting, and view analytics. (This includes Meta App Events).

      

3. How Player Information is Collected

1. Players agree that any and all contact information provided by them is accurate. Spinly is able to collect information in many ways as listed below.

2. Information Players provide directly, whether by visiting the Platform, registering on the Platform, purchasing products on the Platform, responding to any survey or filling out any form, and taking part in any service, activity, or resource Spinly makes available to Players on the Platform.

3. Spinly also collects Players’ information from their phone, video, or through emails, mail, live chat feeds, social media, and text messages. Calls made between Players and any Spinly representatives may be recorded for quality control and training purposes.

4. Using a variety of technology, Spinly collects information about Players’ use of services and products when they visit the Platform or use any third-party sites or platforms (even if Players are not logged in or registered). This includes cookies, pixels, tags, flash cookies, and any API (application programming interfaces).

5. Spinly collects information provided and collected by its trusted third-party services. This may include information used to verify and validate information (postal addresses, documents, or names).

    

4. How the Collected Information is Used

1. The information Spinly collects is used to operate and provide products and services, facilitate financial transactions, and fulfill necessary requirements such as anti-fraud checks, for preventing money laundering and complying with applicable state and federal regulation and legislation.

2. Spinly may collect and use Player information:
   • To process payments (often needed to comply with anti-money laundering regulations and due diligence requirements).
   • To make the user experience more personal.
   • To provide and manage the services requested by Players.
   • To help improve customer service and general services.
   • To send Players important notices, such as communications about purchases, legal notices, and policy changes.
   • To contact Players about Spinly services, including marketing and promotion.
   • For conducting marketing research and analyses.
   • To offer an alternative dispute resolution service.
   • To collect information used for taxation purposes, complying with fraud and anti-money laundering laws, [responsible social gameplay] purposes, and helping to prevent illegal activity.
3. In abiding by global data protection laws, Spinly does not use any automated decision making.
4. Spinly reserves the right to partner with third-party service providers to manage our advertisement on other websites or to display advertising on the Platform. Players must acknowledge the third-party service provider may use technology such as cookies.
5. Players may opt out of this internet-based advertising by Contacting Customer Support.

5. Protecting Player Information

1. Using reasonable means available, Spinly will protect personal information from unauthorized access, modification, disclosure, misuse, or loss.
2. Spinly protects the information it collects from Players utilizing physical, electronic, and operational measures, and regularly reviews and updates its security measures.
3. If there is reason for Spinly to believe that a data breach has occurred, Players will be notified in accordance with regulatory standards.
4. Even with Spinly’s best efforts, the communication of Player data through the Platform can never be guaranteed to be wholly secured. Players transmit personal information at their own risk.

6. Information Sharing

1. In no circumstance does Spinly rent, sell, or trade Players’ personal information to third parties for marketing, promotion, financial or other purposes. Under specific circumstances, Spinly may share Player’s personal data with a third party as necessary for the operation of its services.
2. Spinly requires any third party that it shares Player information with to uphold the same data protection methods that Spinly does.
3. Spinly will only share your information with third parties as necessary for reasons including: providing products/services; when allowed by the Player; when requested by law/public authorities; for due diligence (ID verification); with service providers enabling platform functionality; upon request by a regulator; to detect fraud or illegal activity; or in the event of a business transition (merger, acquisition, etc.).
4. Spinly may share generically collected demographic information with trusted affiliates, advertisers, and business partners.
5. Spinly utilizes a third-party service provider with facial recognition software to verify identity documents. This biometric data is stored until the purpose is satisfied, or within three calendar years of your last interaction with Spinly.
6. The personal information Spinly collects may be stored, processed, maintained and transferred to its affiliates or third parties located within the country, using appropriate safeguards.
7. In the event that a Player wins a Prize, Spinly reserves the right to use that Player’s first name and the first initial of his or her last name for publicity purposes (e.g., “Jane A. won SC 25,000 playing on Spinly”).

7. Player Privacy Rights

1. Players may adjust their preferences for cookies and other trackers.
2. Players have the right to object at any time to Spinly processing their personal information to use in direct advertising by contacting Customer Support.
3. Players may opt out of receiving commercial messages by following the instructions within the message, modifying marketing preferences in their Player Profile, or by contacting Customer Support.

8. Privacy Rights in Action

1. Players have rights including: objecting to data processing, accessing held information, updating/correcting information, and withdrawing consent. In specific circumstances, Players may ask Spinly to delete personal information held.
2. To exercise any of the rights described above, please contact Customer Support.
3. Players will not experience any discrimination from Spinly for choosing to exercise these rights.

4. Spinly reserves the right to request evidence of power of attorney if an authorized agent is used.

5. Nothing within this Privacy Policy restricts Players’ right to lodge a complaint to a supervisory authority.

    

9. Duration of Information Retention

1. Player information collected will be retained for the reasonable time necessary to fulfill the purposes set out in this Privacy Policy, or as further required by law.
2. When personal information is no longer needed or required by law to be retained, Spinly will take reasonable steps to permanently de-identify or delete it.

10. Information Relating to Minors

1. Spinly never knowingly collects information from minors (individuals under the age of 18). No part of the Platform is designed to attract individuals under the age of 18, and Spinly does not offer any service or products to minors.

For any specific questions regarding personal information and how Spinly uses it, please contact Customer Support.