Privacy Policy

1.Introduction

This Privacy Policy ("Policy") applies to all personal information collected by spinan through the website https://spinan.cam and all related services (collectively, the "Platform"). By registering an account or using any feature of the Platform, you acknowledge that you have read, understood, and agreed to the collection, use, and disclosure of your personal data as described in this Policy.

This Policy should be read in conjunction with our Terms & Conditions, which govern your overall use of the Platform. Where the Terms & Conditions and this Privacy Policy conflict, the provisions of this Privacy Policy shall prevail with respect to data protection matters.

2.Data Controller

For the purposes of applicable data protection laws, the data controller responsible for your personal information is spinan. All inquiries, requests, or complaints regarding your personal data should be directed to:

• Email: [email protected]
• Subject line: "Privacy Inquiry" or "Data Subject Request"

We aim to respond to all data protection inquiries within 5 Business Days.

3.Data We Collect

spinan collects several categories of personal information to operate your account, process transactions, and comply with legal obligations. The data we collect includes:

3.1 Account Registration Data

• Full name (as shown on your KTP — Indonesian National Identity Card);
• Date of birth;
• Email address;
• Mobile phone number;
• Username and password (stored in hashed form);
• Residential address in Indonesia.

3.2 KYC Verification Documents

• KTP photograph or scanned copy showing your name, photograph, date of birth, and ID number;
• Selfie photograph holding your KTP (for identity verification);
• Bank account statement or utility bill (for proof of address);
• Bank account details (name, bank, account number) for withdrawal processing.

3.3 Transaction Data

• Deposit amounts, dates, and payment methods (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay);
• Withdrawal requests, amounts, and destination account details;
• Bonus claims and wagering progress;
• Betting history, including stake amounts, odds, selections, and settlement outcomes across sports betting, live casino, togel (Indonesia's traditional lottery game), and slot games.

3.4 Technical Data

• IP address and geolocation data (country and city level);
• Device type, operating system, and browser type;
• Login timestamps and session duration;
• Pages visited, buttons clicked, and features used on the Platform.

3.5 Communications Data

• Live chat transcripts with customer support agents;
• Email correspondence with spinan support or management;
• Feedback, complaints, or survey responses you submit.

4.How We Use Your Data

spinan uses your personal data for the following purposes:

4.1 Account Operation

To create and maintain your account, authenticate your login, and enable you to place bets, make deposits, and request withdrawals.

4.2 KYC Verification & Fraud Prevention

To verify your identity and age (ensuring you are at least 21 years old), to comply with anti-money laundering (AML) regulations, and to detect and prevent fraudulent activity, duplicate accounts, or bonus abuse.

4.3 Transaction Processing

To process your deposits and withdrawals through your chosen payment method, to reconcile payments with your account balance, and to issue refunds or chargebacks where appropriate.

4.4 Customer Support

To respond to your inquiries, resolve disputes, and provide technical assistance via live chat, email, or other support channels.

4.5 Service Improvement

To analyze aggregated and anonymized user behavior data to improve the Platform's design, functionality, and user experience. This includes A/B testing, performance monitoring, and feature development.

4.6 Marketing Communications (With Consent)

Where you have opted in, to send promotional offers, bonus announcements, and updates about new games or features via email or SMS. You may withdraw your consent at any time by contacting support or using the unsubscribe link in our emails.

4.7 Legal Compliance

To comply with legal obligations, including responding to lawful requests from law enforcement, tax authorities, or regulatory bodies; to enforce our Terms & Conditions; and to protect our legal rights in disputes or investigations.

5.Legal Basis for Processing

Under applicable data protection principles, spinan processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to fulfill our contract with you (the Terms & Conditions), including account creation, transaction processing, and customer support.
• Legal Obligation: Processing is required to comply with AML regulations, age verification laws, tax reporting, and lawful requests from authorities.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, and service improvement, provided those interests do not override your fundamental rights.
• Consent: Where we seek your explicit consent (e.g., for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

6.Data Sharing & Third Parties

spinan does not sell your personal data. However, we may share your data with trusted third parties under the following circumstances:

6.1 Payment Processors

We share transaction data with payment service providers (including Indonesian banks such as BCA, BRI, BNI, Mandiri, and e-wallet operators such as OVO, DANA, GoPay) to process deposits and withdrawals. These providers process your data under their own privacy policies and are contractually bound to protect it.

6.2 Game Providers

When you play games supplied by third-party providers (such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe), limited session data (such as your user ID and bet amounts) is shared with those providers to operate the games and settle bets. Game providers do not receive your KTP details or bank account information.

6.3 KYC & Fraud Prevention Services

We may share KYC documents and transactional data with identity verification and fraud detection services to confirm your identity and detect suspicious activity. These services operate under strict data protection agreements.

6.4 Legal Authorities

We may disclose your data to law enforcement, tax authorities, or regulatory bodies where required by law, court order, or legal process. Where permitted, we will notify you of such disclosures unless notification is prohibited or would undermine a lawful investigation.

6.5 Business Transfers

In the event of a merger, acquisition, or sale of all or part of spinan's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections outlined in this Policy.

7.Data Security

spinan employs a range of technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction:

• SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS protocols.
• Database Encryption: Sensitive data (including KTP numbers and bank account details) is encrypted at rest in our databases.
• Access Controls: Access to personal data is restricted to authorized personnel who require it to perform their job functions. All access is logged and audited.
• Password Hashing: User passwords are hashed using industry-standard algorithms (bcrypt or Argon2) and are never stored in plain text.
• Regular Security Audits: We conduct regular vulnerability assessments and penetration testing to identify and remediate security risks.
• Incident Response: In the event of a data breach, we have protocols in place to contain the breach, assess the impact, notify affected users, and report the incident to relevant authorities as required by law.

While we implement robust security measures, no system is completely invulnerable. You are responsible for maintaining the confidentiality of your login credentials and for notifying us immediately if you suspect unauthorized access to your account.

8.Data Retention

spinan retains your personal data for as long as necessary to fulfill the purposes outlined in this Policy or to comply with legal, regulatory, or contractual obligations:

• Active Accounts: While your account is active, we retain all associated data to operate your account and provide services.
• Closed Accounts: After you close your account, we retain KYC documents, transaction records, and betting history for 7 years to comply with AML regulations, tax reporting requirements, and audit obligations.
• Marketing Data: If you have consented to marketing communications, we retain your contact preferences until you withdraw consent or close your account.
• Legal Hold: Where data is subject to a legal hold (e.g., due to pending litigation or regulatory investigation), we will retain that data until the hold is lifted, even if it exceeds the standard retention period.

Once the retention period expires and no legal hold applies, we securely delete or anonymize your data in accordance with data protection best practices.

9.Your Rights

You have the following rights with respect to your personal data:

9.1 Right to Access

You may request a copy of all personal data we hold about you. We will provide this information in a structured, commonly used, and machine-readable format (typically PDF or CSV) within 30 days of your request.

9.2 Right to Rectification

If any personal data we hold is inaccurate or incomplete, you have the right to request correction. You can update most account details directly through your account settings or by contacting support.

9.3 Right to Erasure ("Right to Be Forgotten")

You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and consent was the legal basis), or where you object to processing. This right is subject to our legal obligations to retain certain data for AML and audit purposes.

9.4 Right to Restriction

You may request that we restrict processing of your data in certain circumstances, such as while we verify the accuracy of disputed data or assess whether our legitimate interests override your rights.

9.5 Right to Data Portability

Where technically feasible, you may request that we transfer your data directly to another service provider in a machine-readable format.

9.6 Right to Object

You may object to processing based on legitimate interests or for direct marketing purposes. If you object to marketing, we will cease such processing immediately.

9.7 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 based on consent before its withdrawal.

Exercising Your Rights: To exercise any of these rights, contact our support team at [email protected] with the subject line "Data Subject Request" and specify which right you wish to exercise. We will respond within 30 days and may request additional information to verify your identity before processing your request.

10.Cookies & Tracking Technologies

spinan uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that allow us to recognize you on subsequent visits and to remember your preferences.

10.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function, including session management and authentication. These cannot be disabled.
• Performance Cookies: Collect anonymous data on how users interact with the Platform (e.g., pages visited, time spent) to improve functionality.
• Functional Cookies: Remember your preferences (e.g., language, timezone, display settings) to enhance usability.
• Targeting Cookies: Used to deliver relevant promotional content. These require your consent and can be managed through your browser settings.

10.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can block or delete cookies; however, doing so may impair certain features of the Platform. For more information on managing cookies, consult your browser's help documentation.

11.Third-Party Links

The Platform may contain links to third-party websites, including payment processors, game providers, and support resources. spinan is not responsible for the privacy practices of these external sites. We encourage you to review the privacy policies of any third-party site you visit.

12.Children's Privacy

spinan does not knowingly collect personal data from individuals under the age of 21. Our services are restricted to adults aged 21 and older. If we become aware that we have inadvertently collected data from a person under 21, we will delete that data immediately and close the associated account. Parents or guardians who believe their child has provided personal information to spinan should contact us at [email protected].

13.International Data Transfers

spinan's servers and databases are hosted in jurisdictions with robust data protection frameworks. In some cases, your data may be transferred to, or processed by, service providers located outside Indonesia. Where such transfers occur, we ensure that appropriate safeguards are in place, including:

• Standard contractual clauses approved by international data protection authorities;
• Service provider certifications (e.g., ISO 27001, SOC 2) demonstrating adherence to data protection standards;
• Data processing agreements that impose equivalent privacy obligations on our service providers.

14.Changes to This Privacy Policy

spinan reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. Where changes are material, we will notify registered users via email or a prominent notice on the Platform at least 7 days before the updated Policy takes effect. Your continued use of the Platform after the effective date constitutes acceptance of the revised Policy. We recommend reviewing this page periodically to stay informed of any updates.

15.Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data protection practices, please contact us:

• Email: [email protected]
• Subject line: "Privacy Inquiry" or "Data Subject Request"
• Response time: We aim to respond to all privacy inquiries within 5 Business Days.

For general account inquiries or support, visit our FAQ page or contact our 24/7 live chat team.