1 About This Privacy Policy
This Privacy Policy explains how Spinoy collects, uses, stores, and protects the personal information of players and visitors to the Spinoy platform. It applies to all interactions with Spinoy — whether you browse the website without registering, create a Spinoy account, deposit and play games, use customer support, or participate in promotions.
Spinoy is committed to handling your personal data responsibly and transparently. This policy is written in plain language so that every Filipino player can understand what happens to their information — not just legal professionals. Kung may tanong ka, makakamit mo ang sagot dito.
By using Spinoy, you confirm that you have read this Privacy Policy and consent to the collection and use of your personal data as described here. This policy forms part of Spinoy's Terms and Conditions.
This policy is governed by and consistent with the Republic of the Philippines Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. Spinoy is the data controller responsible for your personal information.
2 Information We Collect
Spinoy collects different types of personal information depending on how you interact with the platform. Below is a clear breakdown of what we collect and when we collect it.
Information You Provide Directly
When you register a Spinoy account or use our services, you provide:
- Full legal name (as it appears on your government-issued ID)
- Date of birth
- Email address
- Philippine mobile number
- Residential address
- Government-issued ID details (for identity verification / KYC purposes)
- Payment method details (GCash number, bank account details, card information as applicable)
- Profile preferences and account settings you configure
Information Collected Automatically
When you use Spinoy, we automatically collect certain technical and behavioural data:
- IP address and approximate geographic location
- Device type, operating system, and browser information
- Pages visited, time spent, and navigation paths within the Spinoy platform
- Login timestamps and session durations
- Game play history, bet amounts, game outcomes, and transaction logs
- Communications with Spinoy customer support (chat logs, email threads)
Information from Third Parties
In some cases, Spinoy may receive personal information about you from third parties — for example, identity verification partners who confirm your ID documents, payment processors who confirm transaction status, or fraud detection services that flag unusual account activity. This information is used only to improve the security and integrity of your Spinoy account.
| Data Category | Examples | When Collected |
|---|---|---|
| Identity Data | Full name, date of birth, government ID | Registration & KYC verification |
| Contact Data | Email address, mobile number, home address | Registration |
| Financial Data | GCash number, bank details, transaction history | Deposits & withdrawals |
| Technical Data | IP address, device type, browser, session data | Every platform visit |
| Gaming Data | Bet history, game outcomes, wagering activity | During gameplay |
| Communications Data | Support chat logs, email correspondence | Customer support interactions |
3 How We Use Your Personal Data
Spinoy uses your personal data only for specific, legitimate purposes. We do not use your data in ways you would not reasonably expect from a Filipino online gaming platform. The following explains the main purposes for which Spinoy processes your information.
Account Management and Service Delivery
Your registration details are used to create and maintain your Spinoy account, verify your identity, process your deposits and withdrawals, settle your bets, and communicate essential account-related information such as transaction confirmations, account alerts, and policy updates.
Identity Verification (KYC)
Philippine gaming regulations require Spinoy to verify the identity of all players before allowing withdrawals above certain thresholds. Your government ID details and selfie verification are used solely for this compliance purpose. KYC data is handled with a higher level of security and access restriction than standard account data.
Fraud Prevention and Security
Spinoy analyses technical data, transaction patterns, and gameplay behaviour to detect and prevent fraudulent activity, money laundering, account takeovers, and the use of automated tools or bots. This protects both individual players and the integrity of the Spinoy platform as a whole.
Responsible Gaming
Spinoy uses your gaming activity data — including session lengths, bet sizes, deposit frequency, and win/loss patterns — to identify early signs of problematic gambling behaviour. If the platform detects concerning patterns, our responsible gaming team may reach out proactively. This is one of the most important uses of your data at Spinoy: it exists specifically to protect you.
Promotions and Communications
If you have opted in to receive marketing communications, Spinoy may use your contact details to send you information about promotions, bonuses, new games, and platform updates. You can opt out of marketing communications at any time through your account settings or by contacting support. Opting out will not affect the delivery of essential service communications.
Platform Improvement
Aggregated, anonymised usage data helps Spinoy understand how players navigate the platform, which features are most used, and where improvements are needed. This data does not identify individual players and is used purely to improve the Spinoy experience for everyone.
4 Legal Basis for Processing Your Data
Under the Philippine Data Privacy Act of 2012, Spinoy processes your personal data based on the following legal grounds:
- Contractual necessity: Processing required to fulfil Spinoy's obligations under your account agreement — including operating your account, processing transactions, and settling bets.
- Consent: Where you have given specific, informed consent — for example, opting in to receive promotional communications.
- Legal obligation: Processing required to comply with Philippine laws and regulations, including anti-money laundering requirements and gaming regulations.
- Legitimate interests: Processing necessary for Spinoy's legitimate business interests — including fraud prevention, platform security, and responsible gaming monitoring — provided those interests are not overridden by your rights and freedoms.
5 Sharing Your Personal Information
Spinoy does not sell your personal data. Period. We share your information only in the circumstances described below, and always with appropriate safeguards in place.
Service Providers and Partners
Spinoy works with trusted third-party service providers who process data on our behalf under strict contractual obligations. These include payment processors (such as GCash, Maya, and card network partners), identity verification providers, cloud hosting services, customer support platform providers, and fraud detection services. These parties are permitted to use your data only for the specific purposes for which they are engaged and must comply with applicable data protection laws.
Regulatory and Legal Requirements
Spinoy will disclose your personal information to government authorities, law enforcement agencies, or regulatory bodies when required to do so by applicable Philippine law — for example, in connection with anti-money laundering investigations, tax reporting obligations, or court orders. We will notify you of such disclosures where we are legally permitted to do so.
Business Transfers
In the event of a merger, acquisition, or sale of all or part of Spinoy's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified before your data is subject to a different privacy policy as a result of such a transfer.
Spinoy will never share your personal data with third parties for their own marketing purposes without your explicit consent. We do not participate in data broker arrangements or sell personal information to advertisers.
6 Cookies and Tracking Technologies
Spinoy uses cookies and similar tracking technologies to improve your platform experience, maintain your login session, and understand how players use the site. Here is a plain-language breakdown of the types of cookies we use.
- Essential cookies: Required for the platform to function. These include session cookies that keep you logged in during your visit. You cannot opt out of essential cookies without losing core platform functionality.
- Analytics cookies: Help Spinoy understand aggregate usage patterns — which pages are visited most, how long sessions last, and where players drop off. This data is anonymised and used only to improve the platform.
- Functional cookies: Remember your preferences — such as language settings or last-visited game categories — to personalise your Spinoy experience.
- Security cookies: Used by Spinoy's fraud detection systems to identify unusual activity patterns that may indicate account compromise or automated tool use.
You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect platform functionality. Spinoy does not use cookies to serve third-party advertising.
7 How Long We Keep Your Data
Spinoy retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, comply with legal and regulatory obligations, and resolve any disputes that may arise.
As a general guide:
- Active account data is retained for the lifetime of your Spinoy account.
- Transaction and betting history is retained for a minimum of five (5) years after the transaction date, in line with Philippine anti-money laundering regulations.
- KYC and identity documents are retained for the period required by applicable gaming and financial regulations, typically five (5) years after account closure.
- Customer support communications are retained for three (3) years after the interaction.
- Marketing consent records are retained for as long as your consent is active plus three (3) years after you withdraw consent.
When your data is no longer required for any of the above purposes, Spinoy will securely delete or anonymise it.
8 How We Protect Your Data
Data security is taken seriously at Spinoy — not just because the law requires it, but because the trust of Filipino players is the foundation the platform is built on. Here is an overview of the security measures in place.
- All data transmitted between your device and Spinoy's servers is encrypted using TLS (Transport Layer Security).
- Sensitive data — including payment information and identity documents — is stored in encrypted form at rest.
- Access to personal data is restricted to authorised Spinoy personnel on a need-to-know basis. Access logs are maintained and reviewed regularly.
- Spinoy's systems undergo regular security assessments and penetration testing.
- Spinoy maintains an incident response procedure. In the event of a data breach that may affect your rights, we will notify you and the National Privacy Commission within the timeframe required by Philippine law.
No internet-based system can guarantee 100% security. While Spinoy does everything technically reasonable to protect your data, you also play an important role — keep your password strong and never share your login credentials with anyone.
9 Your Rights as a Data Subject
Under the Philippine Data Privacy Act of 2012, you have specific rights regarding your personal data. Spinoy is committed to respecting and facilitating these rights. You do not need a lawyer to exercise them — you just need to contact us.
Right to Access
Request a copy of the personal data Spinoy holds about you and receive information about how it is being used.
Right to Rectification
Request correction of any inaccurate or incomplete personal data that Spinoy holds about you.
Right to Erasure
Request deletion of your personal data where there is no legitimate reason for Spinoy to continue processing it — subject to legal retention obligations.
Right to Object
Object to Spinoy processing your personal data for direct marketing purposes, or where processing is based on legitimate interests.
Right to Data Portability
Request a copy of your personal data in a commonly used, machine-readable format that you can transfer to another service provider.
Right to Withdraw Consent
Withdraw consent for marketing communications or other consent-based processing at any time, without affecting the lawfulness of prior processing.
To exercise any of these rights, email Spinoy's Data Protection Officer at support@spinoy.best with the subject line "Data Privacy Request" and a clear description of your request. Spinoy will respond within 15 business days of receiving a valid request, consistent with requirements under Philippine law.
If you are not satisfied with Spinoy's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.
10 Children's Privacy
Spinoy's services are intended exclusively for adults aged 21 years and above. Spinoy does not knowingly collect or process personal data from anyone under the age of 21. If Spinoy becomes aware that personal data has been collected from a minor, that data will be deleted immediately and the associated account closed.
If you believe that a minor has registered on Spinoy, please contact us immediately at support@spinoy.best so we can investigate and take appropriate action.
11 Cross-Border Data Transfers
Spinoy primarily stores and processes your personal data within the Philippines. In some cases, data may be processed by service providers located in other countries — for example, cloud infrastructure providers or international payment processors.
When personal data is transferred outside the Philippines, Spinoy ensures that appropriate safeguards are in place — including contractual data protection provisions that require overseas processors to maintain standards equivalent to those required by Philippine law. Spinoy will not transfer your personal data to countries without adequate data protection frameworks without your consent or a valid legal basis.
12 Third-Party Links
The Spinoy platform may contain links to third-party websites or services — for example, links to payment provider websites during a transaction flow. Spinoy is not responsible for the privacy practices of those third-party sites. We recommend reviewing the privacy policy of any third-party site you visit. This Privacy Policy applies only to the Spinoy platform and its directly operated services.
13 Changes to This Privacy Policy
Spinoy may update this Privacy Policy from time to time to reflect changes in the law, our business practices, or the services we offer. When material changes are made, we will notify registered players via email at least seven (7) days before the new policy takes effect, except where immediate changes are required for legal or security reasons.
The "Last Updated" date at the top of this page reflects the date of the most recent revision. Continued use of Spinoy after the effective date of any revision constitutes your acceptance of the updated policy. If you do not agree with the revised policy, you should stop using Spinoy and request account closure.
14 Contact Us and Data Protection Officer
If you have any questions about this Privacy Policy, want to exercise your data subject rights, or wish to raise a concern about how Spinoy handles your personal information, please contact us through the following channel:
Data Protection Officer, Spinoy
Email: support@spinoy.best
Subject line: Data Privacy Request
Spinoy aims to respond to all data privacy inquiries within 15 business days. For urgent security concerns — such as suspected unauthorised access to your account — please contact us immediately and mark your message as urgent.
You also have the right to bring a complaint to the National Privacy Commission of the Philippines if you believe your data rights have been violated. Information about the NPC's complaint process is available on the NPC's official website.