Privacy Policy — spinml

Who We Are

spinml operates spinml.net, a PAGCOR-regulated online casino and sports betting platform serving Filipino players across the Philippines. As the operator of this Platform, spinml acts as the Data Controller in respect of all personal data collected from players and visitors to spinml.net.

This Privacy Policy applies to all personal data processed by spinml in connection with your use of the Platform — including registration, account management, game play, deposits and withdrawals, customer support interactions, and marketing communications.

Data We Collect

spinml collects personal data through several touchpoints. We are committed to data minimisation — we collect only what is genuinely necessary for the purpose stated. The categories of personal data we collect include:

• Identity data: Full legal name, date of birth, nationality, and gender.
• Contact data: Philippine mobile number, email address, and residential address (city/province).
• Login credentials: Username and hashed password. spinml never stores passwords in plain text.
• Referral source: How you first heard about spinml, if voluntarily provided.

• Government-issued ID: A copy of your Philippine passport, UMID, SSS ID, driver's license, or PhilSys National ID submitted during identity verification.
• Proof of address: A utility bill or bank statement in your name, where required for enhanced due diligence.
• Selfie or liveness check: A photo verification may be requested to confirm that the ID belongs to you.

• Payment method details: GCash number, PayMaya account reference, or Philippine bank account details (BPI, BDO, Metrobank) used for deposits and withdrawals. Full card or account numbers are never stored on spinml servers.
• Transaction history: A complete log of all deposits, withdrawals, bonuses, and wager records associated with your account, maintained for PAGCOR compliance purposes.

• Device data: Browser type, operating system, screen resolution, and device identifiers.
• IP address: Used for geolocation checks to verify you are accessing from a permitted jurisdiction and to detect fraudulent or multi-account activity.
• Session data: Pages visited, games played, duration of sessions, and click-stream data used for responsible gaming monitoring and Platform improvement.
• Cookie data: As described in Section 5 of this Policy.

• Records of all customer support interactions via live chat or email, including the content of messages and timestamps.
• Records of your marketing communication preferences and opt-in/opt-out history.

How We Use Your Data

spinml uses the personal data it collects strictly for the purposes set out below. We do not use your data for any purpose incompatible with the original reason it was collected.

Legal Basis for Processing

Under the Philippine Data Privacy Act, spinml must have a valid legal basis for each category of personal data processing. The bases we rely on are:

• Contractual necessity: Processing required to fulfil the contract between you and spinml — including account creation, processing bets, and paying out winnings. Without this processing, spinml cannot provide its services to you.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AMLC reporting obligations under RA 9160, and NPC data governance requirements under RA 10173.
• Legitimate interests: Processing for fraud prevention, multi-account detection, Platform security, and responsible gaming monitoring — where those interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications — SMS, email, and push notifications about spinml promotions, new JILI slot titles, and bonus offers. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Cookies & Tracking Technologies

spinml uses cookies and similar tracking technologies on spinml.net to operate the Platform effectively, maintain your session, and understand how players navigate the site. The cookie categories we use are:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in while you play. You cannot opt out of these without disabling the Platform entirely.
• Functional cookies: Remember your preferences — such as language settings, preferred game lobby view, and responsible gaming limit configurations — across sessions.
• Analytics cookies: Collect anonymised data on page visits, game load times, and navigation paths to help spinml improve the Platform. No personally identifiable information is included in analytics data.
• Security cookies: Used to detect suspicious login patterns, bot activity, and potential fraud attempts on the spinml.net login flow.

spinml does not use third-party advertising cookies or cross-site tracking technologies that would share your browsing behaviour with external ad networks.

Sharing Your Data

spinml does not sell your personal data. We share your data only in the limited circumstances described below, and only to the extent necessary for the stated purpose:

• PAGCOR and regulatory authorities: spinml is legally required to share transaction records, player identity data, and suspicious activity reports with PAGCOR and the Anti-Money Laundering Council (AMLC) upon request or as mandated by law.
• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank receive the minimum financial data necessary to process your deposits and withdrawals. Each processor operates under their own privacy policy and applicable Philippine banking regulations.
• KYC verification providers: spinml may use a third-party identity verification service to assist with document authentication during the KYC process. These providers process data solely on spinml's instruction and under strict data processing agreements.
• Game software providers: JILI Games and other third-party game studios that power games on spinml.net receive anonymised session data (game round IDs, bet amounts, outcomes) for reconciliation and certification purposes. They do not receive your personally identifiable information.
• IT infrastructure providers: Cloud hosting and data centre providers that store spinml's servers are contractually bound to process your data only on spinml's instructions and to maintain security standards equivalent to those described in Section 8.
• Law enforcement: Philippine law enforcement agencies, courts, or government bodies where spinml is required by law or court order to disclose information.

Any third party that processes personal data on spinml's behalf does so under a formal data processing agreement that obligates them to protect your data to the same standard required by the Philippine Data Privacy Act.

International Data Transfers

spinml's primary data infrastructure is located within the Philippines. In certain circumstances — such as where a game software provider or KYC verification partner operates servers in another country — your personal data may be transferred to and processed in a jurisdiction outside the Philippines.

Where such transfers occur, spinml ensures that:

• The destination country has been assessed to provide an adequate level of data protection comparable to the Philippine Data Privacy Act.
• Appropriate contractual safeguards — such as standard contractual clauses approved by the NPC — are in place with the receiving party.
• The transfer is limited to the minimum data necessary for the stated processing purpose.

You may request details of the safeguards in place for any specific international transfer by contacting our Data Protection Officer at the address in Section 14.

Data Security

spinml implements a layered security architecture to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security measures include:

• Encryption at rest and in transit: All personal data stored in spinml's databases is encrypted at rest using AES-256. All data in transit between your device and our servers is protected by TLS 1.3.
• Access controls: Personal data is accessible only to spinml staff with a legitimate operational need. Access is role-based and logged. KYC documents are accessible only to the compliance team under dual-authorisation controls.
• Password hashing: Account passwords are hashed using a cryptographically strong algorithm. Even spinml's own technical team cannot retrieve your plain-text password.
• Two-factor authentication (2FA): All spinml player accounts support SMS OTP-based 2FA. Staff accounts with access to personal data require 2FA as a mandatory control.
• Penetration testing: spinml conducts regular third-party penetration tests of its Platform infrastructure and remediates identified vulnerabilities according to a risk-prioritised schedule.
• Incident response: In the event of a personal data breach that poses a risk to your rights, spinml will notify the National Privacy Commission within 72 hours of discovery and will notify affected players without undue delay, as required by the Data Privacy Act.

Data Retention

spinml retains personal data for as long as your account is active and for the legally required periods thereafter. Our data retention schedule is as follows:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to any individual. Anonymised aggregated data may be retained indefinitely for statistical purposes.

Your Rights Under Philippine Law

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in relation to the personal data spinml holds about you:

• Right to be informed: The right to know that spinml is collecting and processing your personal data, for what purposes, and on what legal basis — as set out in this Privacy Policy.
• Right of access: The right to obtain a copy of the personal data spinml holds about you, along with information about how it is being processed.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected without undue delay.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to spinml's legal retention obligations under PAGCOR and AMLC regulations.
• Right to object: The right to object to processing based on legitimate interests — including profiling for responsible gaming purposes — where you believe your individual circumstances warrant it.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to withdraw consent: Where processing is based on consent (e.g., marketing communications), the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe spinml has processed your data unlawfully.

To exercise any of the above rights, submit a written request to our Data Protection Officer at support@spinml.net with the subject line "Data Subject Request." We will acknowledge your request within 48 hours and respond substantively within 30 calendar days.

Children & Minors

spinml's Platform is strictly for individuals aged 21 years and above, in accordance with PAGCOR's minimum age requirements for online gaming in the Philippines. spinml does not knowingly collect personal data from individuals under 21 years of age.

Age verification is conducted as part of the KYC process for every spinml account. If spinml discovers — through KYC checks, identity verification, or any other means — that an account has been registered by a person under 21, that account will be immediately suspended and all associated personal data will be scheduled for deletion in line with our legal obligations.

If you are a parent or guardian and believe your child has registered an account on spinml.net, please contact us immediately at support@spinml.net. We will investigate and take appropriate action without undue delay.

Third-Party Links & Services

spinml.net may contain links to third-party websites or services — for example, links to PAGCOR's official website for responsible gaming resources, or to game provider demonstration pages. This Privacy Policy applies only to personal data processed by spinml on spinml.net.

spinml is not responsible for the privacy practices of any third-party website. When you navigate away from spinml.net to an external site, we encourage you to review the privacy policy of that site before providing any personal information.

Updates to This Policy

spinml may update this Privacy Policy from time to time to reflect changes in our data processing practices, PAGCOR requirements, NPC guidance, or applicable Philippine law. The effective date at the top of this page will be updated whenever a material change is made.

For material changes — such as changes to the categories of data we collect, new third-party sharing arrangements, or changes to your rights — spinml will notify registered players via the email address on file at least 14 days before the change takes effect. Continued use of the Platform after the effective date constitutes acceptance of the updated Policy.

We recommend bookmarking this page and reviewing it periodically. The current version will always be available at spinml.net/privacy-policy.

Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or spinml's data processing practices, please contact our Data Protection Officer (DPO) through the following channels:

• General Privacy Enquiries & DSARs: support@spinml.net — please use the subject line "Privacy Enquiry" or "Data Subject Request."
• Business & Partnerships: partners@spinml.net
• Response time: Acknowledgement within 48 hours; substantive response within 30 calendar days.

If you are not satisfied with spinml's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph.