Spinsville (the "Company", "we" or "us") offers online gambling services via its in-house brand. In addition to offering services via the Internet (the "Internet Platform"), the Company may from time to time offer its services via alternative platforms such as, (i) mobile gaming platforms, and (ii) Facebook applications (each, an "Alternative Platform").
When you use the Company's services either via an In-House Brand, Internet or an Alternative Platform, you shall be asked to provide personal identifiable information (PII) to the Company.
Personal Identifiable Information Collection
We collect PII when you register and use our gambling services, make customer inquiries, register for information or other services from the Company (including through Facebook applications), or when you respond to communications from us (such as questionnaires or surveys). The PII we'll collect from you may include, for example, your name, email address, home address, telephone number, voice sample (which will not be kept on our records), debit/credit card data, date of birth and other information.
How Your Information is Processed (Purposes)
The PII provided to us will be processed for one or more of the following Purposes:
- To allow us to provide you with gambling services.
- To process any of your requests for information.
- To provide you with member support services.
- To market our services, websites or products or those of other entities existing within the same group of companies in which the Company exists (the Group) or those of any of our business partners and affiliates.
- To notify you about updates to our software and/or services.
- To support any of the intended purposes specifically stated at the time at which you provided the PII.
To Whom Your Information is Disclosed (Recipients)
Your information may be disclosed for processing to any of the following Recipients:
- To any companies within the Group and their employees who have a need to know such information.
- To any third parties which provide services to the Company or their subcontractors in order to allow or enable us to provide you with gambling services, including by way of example payment processors and data verifiers.
- To any third parties who provide the Group services in relation to the operation of the applicable In House Brand.
- To any auditors, contractors or other advisers auditing any of Group's business processes.
- To any third parties who organize events or tournaments on behalf of or in conjunction with any companies within the Group.
- To any potential purchasers or investors in any company within the Group. Any processing performed by any Recipients will, where required by law, be governed by a data processing agreement, preserving any and all of your statutory data protection rights and obligating the Recipients to respect the PII and handle it in accordance with the relevant laws.
- We ensure that your information will not be disclosed to government institutions or authorities except if required by law and regulations.
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Your Rights in Relation to Your PII
We have implemented suitable security policies, rules and technical measures to protect and keep all information under our control from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction or accidental loss. All our employees and data processors who have access to, and are associated with the processing of your PII, are obliged to respect your privacy.
We may send you a permanent cookie when you register with us. A cookie is a small file that can be placed on your computer's hard disk for record-keeping purposes. They help us recognize you when you next visit our website, note the advertisements you click on and the other sites you enter via a link from our website. This allows us to tailor the service we provide to your preferences.
We may also use the data generated from cookies to compile statistical data on your use of our website. Our website uses four types of cookies:
These are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed.
First Party Cookies / Persistent Cookies:
These are set and read only by our website, saved on your computer for a fixed period (usually a year or longer) and are not deleted when the browser is closed. They are used where we need to know who you are for repeat visits. For example, it allows us to store your preferences for the next login (such as user name and/or password).
Third Party Cookies:
These are set by other websites who run content on the page you are viewing. For example, a third party analytics companies who monitors and analyzes our web access.
These are saved during game play to allow quicker and better gaming experience. You are not obliged to accept a cookie from us or from any other website. You can modify your browser to not accept cookies. However, for legitimate security reasons, we may refuse access to specific website content unless you accept the use of a cookie or similar device.
We use a third-party advertising technology to serve advertisements when you visit our websites. This technology uses information about your visits to our websites (not including your name, address, or other personal information), to serve our advertisements to you. In the course of delivering our advertisements, a unique third-party 'cookie' may be placed or recognized on your browser.
We also transmit website usage information about visitors to our websites to the servers of a reputable third party for the purpose of targeting our Internet banner advertisements on this and other websites. To do this, we use 'Web beacons' and 'cookies' provided by our third-party advertisement server. The information that is collected and logged on our behalf is not personally identifiable.
Protection of Minors
The services provided by the Company are not intended for or directed to minors or persons under the age of legal consent. Any person who provides us with PII represents to us that they are 18 years of age or over the age of legal consent in their jurisdiction. We reserve the right to access and verify any PII submitted by or collected from you. If we become aware that a minor has attempted to or has submitted PII, we may not accept this information and may take steps to remove such information from our records.
Since we operate globally, it may be necessary to transfer your PII to Recipients who are located in countries outside the European Union. This may happen if our servers or such Recipients or their servers are based outside the European Union. If you use our services and products while visiting countries outside the European Union or if we transfer your PII to Recipients or Recipients which have their servers located outside the European Union, you hereby consent to said transfer of your PII. The data protection and other laws of these countries may not be as comprehensive as those in the European Union. In these instances we will take steps to ensure that a similar level of protection is given to your PII.
Your PII will not be stored for any longer period than is necessary for the purposes for which it was collected.