Spinania Privacy Policy

Spinania collects personal data that users provide directly or that is gathered automatically during the use of its online services. This information is necessary for the safe and lawful operation of the platform and the delivery of its services.

Categories of Personal Data Collected

• Full name and date of birth
• Contact details, including email address and telephone number
• Residential address and proof of identity documents
• Financial details, including payment method information and transaction records
• Technical data, such as IP address, browser type, and device identifiers
• Behavioural and usage data collected during platform sessions

Purpose of Collection

Personal data is collected to verify user identity, process financial transactions, comply with regulatory obligations, and maintain the integrity of the platform. Spinania operates in accordance with Spanish data protection legislation, including the Ley Orgánica de Protección de Datos Personales y garantía de los derechos digitales (LOPDGDD), and the General Data Protection Regulation (GDPR) as applicable.

Technical and Organisational Safeguards

Spinania applies appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, or disclosure. These measures include encrypted data transmission, access controls, and regular security assessments.

User Rights

Users have the following rights in relation to their personal data:

• The right to access the data held about them
• The right to request correction of inaccurate or incomplete data
• The right to request deletion of personal data, subject to legal retention obligations
• The right to restrict or object to certain types of processing
• The right to data portability where technically feasible

Requests relating to any of the above rights may be submitted through the official support channels available on the platform.

Personal data collected by Spinania is used for specific, clearly defined purposes. All processing activities are carried out on a lawful basis and in a transparent manner, in line with applicable data protection obligations.

Primary Uses of Personal Data

• Account management: To create, maintain, and administer user accounts, and to verify identity in accordance with regulatory requirements.
• Transaction processing: To facilitate deposits, withdrawals, and other financial operations securely and accurately.
• Service improvement: To analyse platform performance, identify technical issues, and enhance the overall user experience.
• Marketing communications: To send relevant promotional materials to users who have provided their consent. Users may withdraw consent for marketing communications at any time.
• Analytics: To understand how users interact with the platform and to inform decisions regarding functionality and content.
• Legal and regulatory compliance: To meet obligations imposed by Spanish gambling authorities, anti-money laundering legislation, and other applicable laws.

Spinania does not use personal data for purposes incompatible with those stated at the time of collection. Data is not sold to third parties for their own commercial use.

Users have the right to access the personal data that Spinania holds about them at any time. Requests for access, correction, or deletion of personal data may be submitted via the platform’s official support channels.

Correction and Deletion Procedures

• Correction: Where a user identifies that the personal data held is inaccurate or outdated, they may request that it be corrected. Spinania will process such requests promptly and confirm when the update has been made.
• Deletion: Users may request the deletion of their personal data. Requests will be assessed in line with legal and regulatory retention obligations. Where deletion is not immediately possible due to such obligations, the data will be restricted from further processing until it can be lawfully removed.

Consent to Security and Payment Processing

By registering and using the Spinania platform, users consent to the following:

• The completion of identity verification and security checks as required by applicable law and internal compliance procedures.
• The processing of payment data by authorised third-party payment service providers, who handle financial transactions on behalf of the platform.

These processes are integral to the lawful and secure operation of the services provided.

The Spinania platform is intended exclusively for individuals aged 18 years and above. Access to, and use of, the platform’s services by persons under this age is strictly prohibited.

Age Verification

Spinania is unable to independently verify the age of every individual who accesses the platform without the submission of appropriate identity documentation. Users are required to provide accurate information regarding their age during the registration process. Where age verification documents are requested, users must comply promptly.

Data Collected from Minors

Spinania does not knowingly collect or process personal data from individuals under the age of 18. If a parent or legal guardian becomes aware that a minor has registered on the platform or submitted personal data without authorisation, they should contact the support team immediately. Upon confirmation, all personal data associated with the minor’s account will be deleted without undue delay.

Any account found to belong to a minor will be suspended and closed in accordance with applicable regulations.

In the course of providing its services, personal data collected by Spinania may be transferred to, and processed in, countries outside Spain or the European Economic Area. Such transfers may occur where Spinania’s partners, service providers, or operational systems are located in other jurisdictions.

Basis for International Transfers

By using the Spinania platform, users consent to the transfer of their personal data to countries in which Spinania’s partners operate. These transfers are carried out only where adequate safeguards are in place to protect the confidentiality and integrity of the data.

Confidentiality Obligations

All third parties and partners that receive or process personal data on behalf of Spinania are contractually required to maintain confidentiality and to apply data protection standards consistent with applicable legislation. Personal data is not shared with international parties beyond what is necessary for the purposes described in this document.

This Privacy Policy constitutes a legally binding document governing the relationship between Spinania and its users in respect of personal data processing. The terms set out herein may alter the scope or legal effects of certain provisions depending on the circumstances in which they apply.

Applicability

This document takes effect at the moment a user accepts its terms, whether through:

• Electronic acceptance during the registration process
• A formal signature or written acknowledgement
• Continued use of the platform following notification of the policy

Users who do not accept the terms of this Privacy Policy should discontinue use of the platform. Acceptance constitutes agreement to the collection, processing, and use of personal data as described in this document.

Spinania reserves the right to update this document in accordance with changes in applicable law or operational requirements. Users will be notified of material changes through appropriate channels.

Cookies are small text files stored on a user’s device when they visit a website. They are used to retain information across browsing sessions and to support the functionality and performance of online platforms.

How Spinania Uses Cookies

The platform uses cookies for the following purposes:

• Statistical analysis: To collect aggregated data on how users interact with the platform, including pages visited and session duration.
• Behavioural analysis: To identify patterns in user activity that inform platform development and service refinement.
• Personalisation: To remember user preferences and settings, providing a more consistent experience across sessions.
• Site improvement: To detect technical issues and evaluate the effectiveness of changes made to the platform.

Cookie Retention

Cookies placed by Spinania are retained for a period of up to 12 months, after which they expire automatically. Users may manage or disable cookies through their browser settings at any time; however, doing so may affect the functionality of certain features on the platform.

By continuing to use the Spinania platform, users consent to the use of cookies as described above.

By accessing or using the Spinania platform, users confirm that they have read, understood, and accepted the terms of this Privacy Policy in full. Use of any part of the platform’s services constitutes acceptance of this document.

Current Version

This Privacy Policy represents the most recent version of the document and supersedes all previous versions. In the event of any discrepancy between the current version and any earlier iteration, the current version shall prevail.

Spinania reserves the right to amend this Privacy Policy at any time. Where changes are made, the updated document will be published on the platform with the effective date clearly indicated. Users are encouraged to review the policy periodically to remain informed of how their personal data is handled.

In certain circumstances, personal data held by Spinania may be disclosed to third parties. Such disclosures are made only where legally required or otherwise justified, and are conducted in accordance with applicable data protection obligations.

Circumstances Under Which Data May Be Shared

• Legal obligations: Where disclosure is required by law, court order, or a competent regulatory authority, including the Dirección General de Ordenación del Juego (DGOJ).
• Dispute resolution: Where disclosure is necessary to investigate, prevent, or resolve disputes, fraud, or security incidents.
• Contractual arrangements: Where third-party service providers assist in the operation of the platform under binding data processing agreements.

User Consent and Transparency

Where a specific third party receiving personal data is not identified within this document, users will be informed of the purpose and scope of the disclosure prior to or at the time of sharing. By providing personal data and using the Spinania platform, users consent to the sharing of that data as described in this section.

All third parties with access to personal data are required to handle it confidentially and in accordance with the standards set out in their agreements with Spinania.

The Spinania platform may contain links to external websites operated by third parties. These links are provided for informational or operational purposes and do not constitute an endorsement of the content, services, or privacy practices of those websites.

Responsibility for External Content

Spinania has no control over the privacy policies, data collection practices, or security measures of external websites. Each third-party website is governed by its own privacy policy, for which Spinania accepts no responsibility.

User Caution

Users are advised to exercise caution when navigating to external websites accessed via links on the platform. It is recommended that users review the privacy policy of any external site before submitting personal data or engaging with its services. Spinania cannot be held liable for how personal data is collected, used, or stored by any third-party website.