spinph.com Privacy Policy

1 Introduction

1.1 spinph.com is committed to protecting the privacy and personal data of all users of its platform. We understand that trust is the foundation of any relationship between a gaming platform and its players, and we take our data protection obligations seriously.

1.2 This Policy applies to all personal data collected by spinph.com through the spinphcom.org website, mobile applications, customer support interactions, and any other touchpoints through which you interact with spinph.com.

1.3 This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations ("IRR"), as administered by the National Privacy Commission ("NPC") of the Philippines.

1.4 Please read this Policy carefully. If you have any questions about how spinph.com handles your personal data, you may contact our Data Protection Officer using the details provided in Section 14 of this Policy.

2 Data Controller

2.1 For the purposes of the Philippine Data Privacy Act of 2012, spinph.com is the personal information controller in respect of the personal data collected through the spinphcom.org platform.

2.2 spinph.com has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO at the email address provided in Section 14.

2.3 spinph.com is registered with the National Privacy Commission of the Philippines in accordance with applicable registration requirements for personal information controllers handling sensitive personal information.

3 Personal Data We Collect

3.1 spinph.com collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is collected. The categories of personal data we collect include:

3.2 Sensitive Personal Information. In the course of identity verification and compliance with anti -money laundering regulations, spinph.com may collect sensitive personal information as defined under the DPA, including government-issued identification documents and financial account details. Such sensitive personal information is collected only to the extent required by law or necessary to provide the services, and is subject to heightened security measures.

3.3 spinph.com does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

4 How We Use Your Personal Data

4.1 spinph.com uses your personal data only for the purposes for which it was collected, or for compatible purposes that you would reasonably expect. The primary purposes for which we process your personal data are:

• Account Management: To create, maintain, and manage your spinph.com account, including verifying your identity and age (21+), processing your registration, and enabling you to log in securely;
• Service Delivery: To provide you with access to spinph.com's gaming products, including casino games, sports betting, bingo, slots, and other features available on the platform;
• Payment Processing: To process deposits and withdrawals via GCash, Maya, bank transfer, and debit card, and to maintain accurate financial records of your transactions;
• KYC & Compliance: To verify your identity, conduct due diligence, and comply with anti-money laundering (AML), counter-terrorism financing (CTF), and other applicable Philippine regulatory requirements;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Responsible Gaming: To monitor gaming behavior, identify potential problem gambling patterns, and administer responsible gaming tools such as deposit limits and self-exclusion;
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the platform;
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of spinph.com;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.

4.2 spinph.com will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by applicable law.

5 Legal Basis for Processing

5.1 Under the Philippine Data Privacy Act of 2012, spinph.com processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and spinph.com (i.e., the Terms & Conditions you agreed to upon registration), including account management, service delivery, and payment processing;
• Legal Obligation: Processing is necessary to comply with applicable Philippine laws and regulations, including AML/CTF requirements, PAGCOR-related regulatory obligations, and the Data Privacy Act itself;
• Legitimate Interests: Processing is necessary for spinph.com's legitimate interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms;
• Consent: For certain processing activities, such as marketing communications and non-essential cookies, spinph.com relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

6 Data Sharing & Disclosure

6.1 spinph.com does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary:

• Payment Processors: GCash, Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your deposits and withdrawals;
• Identity Verification Providers: Third-party KYC service providers who assist spinph.com in verifying your identity and age in compliance with regulatory requirements;
• Game Software Providers: Licensed game developers and providers whose games are available on the spinph.com platform, to the extent necessary to deliver the gaming service;
• Regulatory Authorities: The National Privacy Commission, PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where required by law or regulatory obligation;
• IT & Security Service Providers: Cloud hosting, cybersecurity, and technical infrastructure providers who process data on behalf of spinph.com under strict data processing agreements;
• Professional Advisors: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

6.2 All third parties with whom spinph.com shares personal data are required to handle that data in accordance with the Philippine Data Privacy Act and spinph.com's data protection standards. spinph.com enters into data sharing or data processing agreements with such parties as required by law.

6.3 spinph.com may disclose your personal data if required to do so by law, court order, or in response to a valid request from a Philippine government authority.

7 Data Retention

7.1 spinph.com retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulation.

7.2 The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements;
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations;
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship;
• Customer Support Records: Retained for three (3) years from the date of the last interaction;
• Marketing Consent Records: Retained until you withdraw consent, plus a reasonable period thereafter for compliance documentation purposes.

7.3 When personal data is no longer required, spinph.com will securely delete or anonymize it in accordance with its data disposal procedures.

8 Your Rights as a Data Subject

8.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by spinph.com:

• Right to Be Informed: You have the right to be informed of how your personal data is being collected and processed, as described in this Policy;
• Right to Access: You have the right to request a copy of the personal data spinph.com holds about you, along with information about how it is being used;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data spinph.com holds about you;
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to spinph.com's legal retention obligations;
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

8.2 To exercise any of the above rights, please contact spinph.com's Data Protection Officer using the contact details in Section 14. spinph.com will respond to your request within fifteen (15) business days, as required by the DPA IRR.

8.3 spinph.com may need to verify your identity before processing certain data subject requests to ensure the security of your personal data.

9 Cookies & Tracking Technologies

9.1 spinph.com uses cookies and similar tracking technologies to enhance your experience on the platform, remember your preferences, and analyze how the platform is used. A cookie is a small text file placed on your device when you visit spinph.com.

9.2 The types of cookies used by spinph.com include:

• Strictly Necessary Cookies: Essential for the platform to function correctly, including session management and security features. These cannot be disabled;
• Functional Cookies: Remember your preferences such as language settings and login status to provide a more personalized experience;
• Analytics Cookies: Collect anonymized data about how users interact with spinph.com to help us improve the platform's performance and usability;
• Marketing Cookies: Used to deliver relevant promotional content and track the effectiveness of spinph.com's marketing campaigns, subject to your consent.

9.3 You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the spinph.com platform.

10 Data Security

10.1 spinph.com implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and spinph.com;
• Encryption of sensitive data at rest, including financial information and government ID details;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for account access and administrative systems;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

10.2 In the event of a personal data breach that is likely to result in harm to affected individuals, spinph.com will notify the National Privacy Commission and affected data subjects within seventy-two (72) hours of becoming aware of the breach, as required by the DPA.

10.3 While spinph.com takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for keeping your spinph.com login credentials confidential and for notifying us immediately of any suspected unauthorized access to your account.

11 Children's Privacy

11.1 spinph.com is strictly intended for individuals aged 21 years and above. We do not knowingly collect, use, or store personal data from persons under the age of 21.

11.2 If spinph.com becomes aware that personal data has been collected from a person under 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account.

11.3 If you are a parent or guardian and believe that your child under the age of 21 has provided personal data to spinph.com, please contact us immediately using the details in Section 14 so that we can take appropriate action.

12 Third-Party Links

12.1 The spinph.com platform may contain references to third-party services, such as payment processors and game providers. spinph.com is not responsible for the privacy practices of these third parties and encourages you to review their respective privacy policies before providing any personal data to them.

12.2 This Policy applies solely to personal data collected and processed by spinph.com through the spinphcom.org platform and does not extend to any third-party websites, applications, or services.

13 Updates to This Policy

13.1 spinph.com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is indicated at the top of this document.

13.2 Where changes to this Policy are material, spinph.com will notify registered users via the email address or mobile number on file prior to the changes taking effect.

13.3 Your continued use of spinph.com following the effective date of any updated Policy constitutes your acknowledgment of the changes. If you do not agree to the updated Policy, you should cease using spinph.com and may request account closure.

14 Contact Our Data Protection Officer

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by spinph.com, please contact our Data Protection Officer:

14.2 You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.

14.3 For responsible gaming concerns, please visit our Responsible Gaming page for tools and support resources available to spinph.com players.