spin ph Privacy Policy

1. Who We Are

spin ph is the operator of the online gaming platform accessible at spinph.asia (the "Platform"). spin ph functions as the Personal Information Controller (PIC) in respect of all personal data collected from users of the Platform, within the meaning of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations ("IRR").

spin ph operates under the supervisory framework of the Philippine Amusement and Gaming Corporation (PAGCOR). In that capacity, certain personal data processing obligations are also mandated by PAGCOR's licensing conditions and applicable Philippine Anti-Money Laundering (AML) legislation, including the Anti-Money Laundering Act (RA 9160, as amended) and the rules of the Anti-Money Laundering Council (AMLC).

If you have any questions about how spin ph handles your personal data, you may contact us at any time through the channels listed in Section 15 of this Policy.

2. Scope of This Privacy Policy

This Privacy Policy applies to all personal data collected by spin ph in connection with your use of the Platform, including when you:

• Visit or browse the spinph.asia website, including unauthenticated browsing;
• Register an Account with spin ph;
• Complete KYC (Know Your Customer) verification;
• Make a deposit or request a withdrawal using GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, or other accepted payment channels;
• Play any game or place any bet on the Platform;
• Contact spin ph's customer support team via live chat, email, or any other channel;
• Participate in any spin ph promotion, bonus, or loyalty programme;
• Receive any communication from spin ph, including marketing messages you have consented to receive.

This Policy does not govern the data practices of third-party game providers, payment processors, or other third-party services that may be linked to or integrated with the Platform. Where such third parties are involved in processing your data, they do so under their own privacy policies, over which spin ph has no control.

3. Personal Data We Collect

spin ph collects only the personal data that is necessary and proportionate to the purposes for which it is processed. The categories of personal data we collect are set out in the table below.

3.1 Sensitive Personal Information

The DPA classifies certain categories of data as "sensitive personal information" requiring a heightened standard of care. In the course of KYC verification, spin ph may collect data that falls within this classification — specifically, government-issued ID numbers. spin ph processes such data solely for the purposes of identity verification, age verification, AML compliance, and fraud prevention, and applies additional technical and organisational safeguards to sensitive data.

4. How We Collect Your Data

spin ph collects personal data through the following means:

4.1 Directly From You

• When you complete the Account registration form on the spin ph Platform;
• When you submit KYC documents for identity and age verification;
• When you make a deposit or submit a withdrawal request;
• When you contact spin ph's support team, provide feedback, or respond to a survey;
• When you update your Account profile or responsible gaming settings.

4.2 Automatically When You Use the Platform

• Via web server logs that record your IP address, browser, and access timestamps;
• Via cookies, session storage, and similar tracking technologies placed on your device (see Section 8);
• Via analytics tools that record navigation patterns and feature usage on the Platform.

4.3 From Third Parties

• From payment service providers (e.g., GCash, PayMaya, BPI, BDO) in the course of processing your transactions — limited to transaction confirmation data;
• From identity verification partners engaged by spin ph to assist with KYC or fraud screening;
• From PAGCOR or Philippine government agencies where required by law or regulatory direction.

5. Why We Process Your Personal Data

spin ph processes your personal data for the following specific purposes:

• Account management: To create, maintain, and administer your spin ph Account, including processing your login credentials and Account settings;
• Identity and age verification (KYC): To verify that you are who you say you are and that you are at least 21 years of age, as required by PAGCOR regulations;
• Transaction processing: To process deposits and withdrawals through your chosen payment method, reconcile transactions, and investigate disputes;
• AML and fraud prevention: To monitor for activity consistent with money laundering, fraud, collusion, or account takeover, as required under Philippine AML law;
• Regulatory compliance: To meet spin ph's obligations to PAGCOR, the AMLC, and other Philippine regulatory bodies, including the filing of mandated reports;
• Game delivery and integrity: To operate, maintain, and secure game features, detect cheating or abuse, and ensure fair play;
• Customer support: To respond to your queries, complaints, and support requests;
• Responsible gaming: To monitor gaming patterns, apply player-set limits, and identify indicators of problem gambling that may require intervention;
• Platform improvement: To analyse usage data and improve the spin ph Platform's performance, design, and game offering;
• Marketing communications: To send you promotional messages, offers, and updates about spin ph — but only where you have given clear consent to receive such communications;
• Legal proceedings: To establish, exercise, or defend legal claims involving spin ph.

6. Legal Basis for Processing

Under the Philippine Data Privacy Act, spin ph must have a lawful basis for each instance of personal data processing. The legal bases we rely on are as follows:

• Contractual necessity: Processing required to perform the contract between you and spin ph — i.e., to provide the gaming services you have requested. This covers Account registration, game play, deposits, and withdrawals;
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and the Data Privacy Act itself. This covers KYC, AML monitoring, and regulatory reporting;
• Legitimate interest: Processing that serves spin ph's legitimate operational interests and is proportionate to those interests, provided it does not override your rights. This covers fraud detection, Platform security, and internal analytics;
• Consent: Where no other legal basis applies, spin ph will seek your explicit consent before processing your data for that purpose. Marketing communications are the primary example. You may withdraw consent at any time without detriment to your Account.

7. Sharing of Personal Data

spin ph does not sell, rent, or disclose your personal data to unaffiliated third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly to the extent necessary:

7.1 Regulated and Required Disclosures

• PAGCOR: As spin ph's regulatory authority, PAGCOR may require the disclosure of Player data in the course of regulatory oversight, audits, or investigations;
• Anti-Money Laundering Council (AMLC): Where applicable, spin ph is legally obligated to file Suspicious Transaction Reports (STRs) and Covered Transaction Reports (CTRs) with the AMLC;
• Law enforcement and courts: Where compelled by a valid court order, subpoena, or legal process under Philippine law.

7.2 Service Providers and Processors

spin ph engages third-party service providers who process personal data on our behalf as Personal Information Processors (PIPs), subject to appropriate Data Processing Agreements (DPAs) under RA 10173. These include:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment intermediaries — to facilitate your deposits and withdrawals;
• KYC and identity verification providers: Third-party KYC services engaged to assist with document verification and age confirmation;
• Game providers: Where game data must be shared with a game provider (e.g., Playtech, JILI, PG Soft) to operate the game and record outcomes;
• Technology and infrastructure providers: Cloud hosting, data storage, and IT security vendors that support the spin ph Platform infrastructure;
• Customer support platforms: Live chat and ticketing systems used to manage your support requests.

8. Cookies & Tracking Technologies

The spin ph Platform uses cookies and similar technologies to operate properly, improve your experience, and analyse Platform usage. A "cookie" is a small text file stored on your device by your browser when you visit a website. Cookies cannot access other files on your device and are not executable programmes.

8.1 Types of Cookies We Use

• Strictly necessary cookies: Required for the Platform to function — including session authentication, security tokens, and anti-CSRF protection. These cannot be disabled without breaking core Platform functionality;
• Functional cookies: Remember your preferences such as language settings, responsible gaming limits, and display preferences to enhance your experience;
• Analytics cookies: Collect anonymous or pseudonymous data about how visitors use the Platform — pages visited, time spent, navigation paths. Used by spin ph to improve the Platform. No personally identifiable information is included in analytics reports;
• Security cookies: Used to detect and prevent fraudulent login activity, account takeover attempts, and bots.

8.2 Managing Cookies

You may configure your browser to reject or delete cookies. However, disabling strictly necessary cookies will prevent you from logging into and using the spin ph Platform. To manage cookie preferences, access your browser's settings menu. Most modern browsers offer granular cookie control by domain and category.

9. Data Security

spin ph implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Encryption in transit: All data transmitted between your device and spin ph servers is encrypted using TLS 1.2 or higher (SSL certificates enforced on all Platform pages);
• Encryption at rest: Sensitive personal data, including KYC documents and financial records, is encrypted at rest in spin ph's storage systems;
• Access control: Access to personal data is restricted to spin ph staff and contractors who have a legitimate operational need for such access, enforced through role-based access control and multi-factor authentication on internal systems;
• Password security: Account passwords are stored as one-way hashed values. spin ph does not store plaintext passwords and cannot retrieve your password — only reset it;
• Vulnerability management: spin ph's systems are subject to regular security assessments, vulnerability scanning, and penetration testing;
• Incident response: spin ph maintains a documented data breach response plan. In the event of a data breach that poses a real risk to your rights, spin ph will notify you and the National Privacy Commission (NPC) within the timeframes mandated by the DPA.

10. Data Retention

spin ph retains personal data only for as long as is necessary for the purposes described in this Policy, or as required by applicable Philippine law. The general retention schedule is as follows:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with spin ph's data disposal procedures. Where data must be retained to comply with a legal hold, court order, or ongoing regulatory investigation, retention will be extended for the duration of that obligation.

11. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by spin ph. These rights are subject to applicable exemptions and legal obligations that may limit their exercise in specific circumstances.

12. Children & Minors

The spin ph Platform is strictly for adults aged 21 years and above. spin ph does not knowingly collect, process, or store personal data from any person under the age of 21, and does not permit any person under 21 to register an Account or participate in real-money gaming.

If spin ph discovers that personal data has been collected from a person under the age of 21, that data will be immediately deleted, the associated Account will be closed, and any deposits or winnings associated with that Account will be handled in accordance with PAGCOR's directives regarding underage gambling.

Parents and guardians who believe their child may have accessed the spin ph Platform should contact spin ph support immediately at [email protected]. spin ph treats underage access notifications as a priority and will investigate and respond promptly.

13. Cross-Border Data Transfers

Some of spin ph's third-party service providers — including cloud infrastructure providers, game developers, and KYC platforms — may be located outside of the Philippines. Where your personal data is transferred to a recipient in a country or jurisdiction other than the Philippines, spin ph takes appropriate steps to ensure that such transfers comply with the DPA and NPC regulations on cross-border data flows.

These steps may include:

• Entering into data transfer agreements that incorporate NPC-approved standard contractual clauses or equivalent data protection obligations;
• Verifying that the recipient country provides an adequate level of data protection comparable to Philippine standards;
• Conducting transfer impact assessments where required.

spin ph will not transfer personal data internationally in a manner that violates the DPA or that could compromise the security or integrity of your information.

14. Updates to This Privacy Policy

spin ph may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or regulatory requirements. Where changes are material — that is, where they could reasonably affect your privacy rights or the way in which your data is processed — spin ph will notify registered Players via a prominent notice on the Platform and, where practicable, by email to your registered address at least 7 days before the changes take effect.

The "Last updated" date displayed at the top of the Table of Contents reflects the date of the most recent revision. We recommend that you review this Policy periodically, particularly before providing any new personal information to spin ph.

Your continued use of the spin ph Platform after the effective date of any revision constitutes your acknowledgement of and agreement to the updated Privacy Policy. If you do not agree to the revised Policy, you must cease using the Platform and contact support to close your Account.

15. Contact Us & Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have a concern about how spin ph has handled your personal information, please contact us through the following channels:

spin ph will acknowledge all privacy-related inquiries within 48 hours and will provide a substantive response within 30 calendar days of receiving a verifiable data subject rights request. Where the complexity of a request requires additional time, spin ph will inform you of the anticipated timeline and the reason for the delay.

If your concern remains unresolved after engaging with spin ph, you may escalate a complaint to the National Privacy Commission (NPC) of the Philippines. The NPC's complaint procedures are published on the NPC's official government portal.