spinco Privacy Policy –
How We Protect Your Data

This Privacy Policy describes how spinco ("spinco," "we," "us," or "the Platform") collects, uses, stores, discloses, and protects the personal information of individuals ("you" or "the Player") who access or use the spinco online gaming platform accessible at spinco.lat.

spinco is committed to protecting your privacy and ensuring the security of your personal data in full compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and all applicable regulations issued by the National Privacy Commission (NPC) of the Philippines. This Privacy Policy also reflects the requirements of the Philippine Amusement and Gaming Corporation (PAGCOR), which licenses and regulates spinco's operations.

By creating an account, accessing the spinco platform, or using any spinco services, you acknowledge that you have read, understood, and consented to the collection, use, and disclosure of your personal information as described in this Privacy Policy.

For the purposes of the Data Privacy Act of 2012, spinco is the data controller responsible for the processing of your personal information. As data controller, spinco determines the purposes and means of processing personal data collected through the spinco platform.

spinco is registered with and regulated by PAGCOR and operates exclusively within the Republic of the Philippines. All data processing activities are conducted in accordance with Philippine law.

Questions regarding data processing or this Privacy Policy may be directed to the spinco Data Protection Officer at the contact details provided in Section 15 below.

spinco collects the following categories of personal information:

3.1 Information You Provide Directly

• Registration Information: Full legal name, date of birth, email address, Philippine mobile number, residential address, and username.
• Identity Verification (KYC) Documents: Government-issued identification (such as Philippine passport, UMID, driver's licence), proof of address, and selfie photographs for identity matching as required by PAGCOR anti-money laundering requirements.
• Payment Information: Bank account details, GCash or PayMaya account information, and transaction history. Note that spinco does not store complete credit card numbers; payment processing is handled by certified third-party payment processors.
• Communications: Content of customer support inquiries, live chat messages, email correspondence, and any other voluntary communications with spinco staff.

3.2 Information Collected Automatically

• Device and Connection Data: IP address, device type, operating system, browser type and version, screen resolution, language settings, and unique device identifiers.
• Usage Data: Pages viewed, games played, bet amounts, game outcomes, session duration, navigation paths, referral sources, and timestamps of activity.
• Location Data: General geographic location inferred from IP address to verify that you are accessing spinco from within the Philippines as required by our PAGCOR licence.
• Cookies and Similar Technologies: Data collected via cookies, web beacons, and local storage as further described in Section 10 below.

3.3 Information from Third Parties

spinco may receive information about you from third-party service providers, including payment processors (confirmation of payment method ownership), fraud prevention services (risk assessment data), and identity verification providers (document authentication results).

spinco processes your personal information for the following purposes:

• Account Creation and Management: To register and maintain your spinco account, authenticate your identity at login, and enable access to gaming services.
• Transaction Processing: To process deposits, withdrawals, and all financial transactions associated with your gameplay and account balance.
• Regulatory Compliance: To verify your age (21+ requirement), conduct KYC due diligence, detect and prevent money laundering and fraud, and comply with PAGCOR reporting and record-keeping obligations.
• Game Operation: To deliver gaming content, process wagers, determine outcomes, credit winnings, and maintain accurate game records.
• Customer Support: To respond to inquiries, resolve disputes, investigate complaints, and provide assistance with account or technical issues.
• Platform Security: To detect and prevent fraud, abuse, cheating, hacking, account takeover, bonus abuse, and other threats to platform integrity or player safety.
• Responsible Gaming: To implement and enforce deposit limits, self-exclusion, session time limits, and other responsible gaming tools; and to identify patterns of potentially problematic gambling behaviour.
• Marketing Communications: With your consent, to send promotional offers, bonus notifications, newsletters, and other marketing communications relevant to your interests. You may opt out at any time.
• Analytics and Improvement: To analyse platform usage, understand player preferences, optimise user experience, develop new features, and improve the overall quality of spinco services.
• Legal Obligations: To comply with court orders, subpoenas, legal process, or lawful requests from Philippine government authorities.

Under the Data Privacy Act of 2012, spinco processes your personal information on the following legal grounds:

• Consent: You have provided explicit consent for spinco to process your personal data when you created your account and accepted this Privacy Policy. Consent is also obtained for marketing communications and optional data processing activities.
• Performance of Contract: Processing is necessary to fulfil the Terms & Conditions governing your use of the spinco platform, including account services, gameplay, and payment processing.
• Legal Obligation: Processing is required to comply with Philippine law, including the Data Privacy Act, Anti-Money Laundering Act (AMLA), and PAGCOR regulatory requirements for age verification, KYC, and transaction monitoring.
• Legitimate Interests: Processing is necessary for spinco's legitimate business interests, such as fraud prevention, platform security, abuse detection, and improving the quality of our services, provided such interests are not overridden by your fundamental rights and freedoms.

spinco does not sell, rent, or trade your personal information to any third party for commercial purposes. We may share your data only in the following circumstances:

6.1 Service Providers

spinco engages trusted third-party service providers who process personal data on our behalf and under our instruction, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank, UnionBank), identity verification providers, fraud detection services, cloud infrastructure providers, and customer support platforms. All service providers are contractually bound to process data only for the purposes instructed by spinco and in compliance with the Data Privacy Act.

6.2 Regulatory Authorities

spinco may disclose personal information to PAGCOR or other Philippine government agencies where required by law, regulation, court order, or official directive. Such disclosures are made to the minimum extent required to satisfy the applicable legal obligation.

6.3 Anti-Money Laundering Compliance

In compliance with the Anti-Money Laundering Act (AMLA) and PAGCOR AML requirements, spinco may be required to report certain transactions or account activities to the Anti-Money Laundering Council (AMLC) of the Philippines. Players will not be notified of such disclosures where notification is prohibited by law.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of spinco's business, your personal data may be transferred to the acquiring or successor entity, subject to that entity assuming the obligations of this Privacy Policy with respect to your data.

spinco retains personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law and PAGCOR regulations:

• Account and KYC Records: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR licensing conditions and AMLA record-keeping obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, consistent with AMLA and Bureau of Internal Revenue (BIR) requirements.
• Game Records: Individual game round records, including bet amounts, game outcomes, and timestamps, retained for a minimum of three (3) years to support dispute resolution and regulatory auditing.
• Customer Support Communications: Retained for two (2) years from the date of the last communication, unless the subject matter gives rise to an ongoing dispute.
• Marketing Consent Records: Retained for the duration of the player's relationship with spinco and for a reasonable period thereafter to demonstrate compliance with consent requirements.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised such that it can no longer be associated with an identifiable individual.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by spinco:

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfils that obligation.
• Right of Access: You may request a copy of the personal data spinco holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate, incomplete, or outdated personal information in your account. Basic details can be updated directly through your account settings.
• Right to Erasure: You may request deletion of your personal data where processing is no longer necessary for the purpose for which it was collected, subject to spinco's legal retention obligations under PAGCOR and AMLA requirements.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes. You may also object to processing based on legitimate interests where your rights and freedoms override those interests.
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe spinco has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact the spinco Data Protection Officer at the details provided in Section 15. spinco will respond to all verified privacy rights requests within fifteen (15) calendar days of receipt.

spinco implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption: All data transmitted between your device and spinco's servers is encrypted using 256-bit SSL/TLS protocols. Sensitive stored data is encrypted at rest.
• Access Controls: Employee access to personal data is limited on a strict need-to-know basis. All access is logged and subject to periodic review.
• Two-Factor Authentication: Available and encouraged for all spinco accounts to prevent unauthorised login.
• Network Security: Firewalls, intrusion detection systems, and regular vulnerability assessments are deployed to protect the spinco infrastructure.
• Data Minimisation: spinco collects only the personal data necessary for the specified purposes and avoids retaining data beyond required periods.
• Staff Training: spinco staff with access to personal data receive regular training on data protection obligations and privacy best practices.
• Incident Response: spinco maintains a data breach response procedure. In the event of a breach affecting your rights, you will be notified and the NPC will be informed in accordance with the Data Privacy Act's breach notification requirements.

spinco uses cookies and similar tracking technologies to operate the platform, personalise your experience, and analyse platform usage. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential to the operation of the spinco platform. These enable core functions such as session authentication, spinco Login functionality, security enforcement, and fraud prevention. These cookies cannot be disabled.
• Functional Cookies: Enable personalisation features such as language preferences, display settings, and game history. These improve your experience but are not strictly essential to basic platform operation.
• Analytics Cookies: Used to understand how players interact with the spinco platform – which pages are visited most, how long sessions last, and where errors occur. This data is aggregated and used to improve platform quality.
• Security Cookies: Used to detect and prevent fraudulent activity, bot traffic, and account compromise attempts.

You may control cookie preferences through your browser settings. Note that disabling certain cookies may impair the functionality of the spinco platform. spinco does not use cookies to serve third-party advertising or track your activity across unrelated websites.

spinco integrates third-party services to deliver certain platform functions, including payment processing, game delivery, identity verification, and customer support. These third-party providers operate under their own privacy policies and data processing agreements.

spinco enters into Data Processing Agreements (DPAs) with all third-party processors that handle personal data on spinco's behalf. These agreements require processors to implement appropriate security measures, process data only for authorised purposes, and comply with the Data Privacy Act of 2012.

spinco is not responsible for the privacy practices of third-party websites or services that are not operated by or on behalf of spinco. Links to external platforms, where they appear, are subject to those platforms' own privacy policies.

spinco is strictly an adult platform available only to individuals aged 21 years and above. spinco does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted at the point of registration and through the KYC process.

In the event that spinco discovers personal data has been collected from an individual under the age of 21, such data will be permanently deleted and the account will be closed immediately. Any real-money deposit made by an underage player will be returned to the payment source used.

spinco's operations are based in the Philippines and personal data is primarily processed and stored within Philippine territory. However, certain third-party service providers (such as cloud infrastructure or game delivery partners) may process data in other jurisdictions.

Where personal data is transferred outside the Philippines, spinco ensures that such transfers comply with the Data Privacy Act's requirements for cross-border data transfers. This includes ensuring that the recipient country provides adequate protection, or that appropriate contractual safeguards (such as standard contractual clauses) are in place prior to the transfer.

spinco does not transfer personal data to jurisdictions where adequate protection cannot be guaranteed without implementing appropriate additional safeguards and obtaining any necessary approvals from the National Privacy Commission.

spinco may update this Privacy Policy from time to time to reflect changes in our data practices, applicable Philippine law, or PAGCOR regulatory requirements. When material changes are made, spinco will notify registered players via email or platform notification at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Privacy Policy indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically to stay informed about how spinco protects your personal information.

Continued use of the spinco platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Privacy Policy, you should cease using the platform and may request account closure in accordance with the spinco Terms & Conditions.

If you have questions about this Privacy Policy, wish to exercise any of your data rights under the Data Privacy Act, or wish to raise a privacy-related complaint, please contact the spinco Data Protection Officer through the following channel:

If you are not satisfied with spinco's response to a privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012. spinco will cooperate fully with any NPC investigation or compliance review.

For account security matters, fraud concerns, or urgent data breach notifications, please contact spinco's 24/7 live support team directly through the spinco platform to ensure the fastest possible response.