Scope

Spinmacho (the Company) collects and processes personal data in connection with our platform and services. This Privacy Policy explains how we obtain, use, store, and protect personal data when you access or use Spinmacho's website, applications, or related services.

Categories of personal data we collect

We may collect and process the following categories of personal data:

• Identity data: first name, last name, date of birth, gender.
• Contact data: email address, postal address, telephone number.
• Account data: username, password, and other registration details.
• Financial data: payment card details, bank account information required to process transactions.
• Verification data: copies of government-issued identification documents for identity and age verification.
• Communication data: records of correspondence with Spinmacho, including emails and in-app messages.
• Technical data: IP address, device and browser information, time zone, operating system, and platform.
• Usage data: information about how you use the Platform, including pages visited, features used, and navigation paths.
• Location data: geolocation information derived from IP address or device settings.
• Data from third parties: information obtained from third party partners in connection with transactions or account verification.

How we collect your personal data

We collect personal data through the following channels:

• Direct interactions: when you register, update your profile, or communicate with us.
• Automated technologies: cookies, server logs, and similar technologies as you engage with the Platform.
• Third-party sources: when you interact with partner providers or service partners for identity verification, payment processing, or fraud prevention.

Purposes and legal bases for processing

We process personal data for the following purposes and on the corresponding legal bases:

• Providing services: to register you, enable betting transactions, and deliver our Services. Legal basis: performance of a contract (Article 6(1)(b) GDPR).
• Identity verification and security: to confirm identity and age, prevent fraud, and protect platform security. Legal basis: compliance with legal obligations (Article 6(1)(c) GDPR) and legitimate interests (Article 6(1)(f) GDPR).
• Customer support: to respond to inquiries and provide support. Legal basis: performance of a contract (Article 6(1)(b) GDPR) and legitimate interests (Article 6(1)(f) GDPR).
• Marketing communications: to send promotional offers, updates, and information. Legal basis: your consent (Article 6(1)(a) GDPR) or legitimate interests where applicable (Article 6(1)(f) GDPR).
• Analytics and product improvement: to analyze usage, improve features, and develop new services. Legal basis: legitimate interests (Article 6(1)(f) GDPR).
• Legal compliance: to comply with applicable laws and regulations, including gambling and anti‑money laundering requirements. Legal basis: compliance with legal obligations (Article 6(1)(c) GDPR).
• Protecting Spinmacho and users: to enforce terms, protect rights, safety, and property. Legal basis: legitimate interests (Article 6(1)(f) GDPR).

Cookies and similar technologies

We use cookies and related technologies to operate the Platform, remember preferences, and analyze usage. Our Cookie Policy provides details on types of cookies, purposes, and how you can manage preferences. We obtain explicit consent before placing non‑essential cookies on your device.

Disclosure of personal data

We may share personal data with the following categories of recipients:

• Service providers: entities that process data on our behalf for payments, verification, IT, and marketing services, under written agreements and data protection safeguards.
• Third-party partners: bookmakers or casinos where you initiate transactions through the Spinmacho Platform, governed by their own privacy policies.
• Regulators and law enforcement: where required by law or to protect our rights or users.
• Business transfers: in the event of a merger, acquisition, or sale of assets, personal data may be transferred to the successor entity.

International data transfers

Spinmacho may transfer personal data to jurisdictions outside the jurisdiction in which you reside, including countries that may not provide an equivalent level of data protection. We rely on adequacy decisions where available, Standard Contractual Clauses, and additional safeguards to protect data in transit and storage.

Data retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Policy and to comply with legal obligations. Retention periods take into account regulatory requirements, contractual obligations, and the expectations of our users. When data is no longer required, we securely delete or destroy it.

Your rights

You have the rights described below in respect of your personal data, subject to applicable laws. To exercise these rights, use the in‑platform contact options or the designated contact method described in the How to Contact Us section.

• Right of access: obtain confirmation of whether we process your data and access the data we hold.
• Right to rectification: request correction of inaccurate or incomplete data.
• Right to erasure: request deletion of data where processing is no longer necessary or unlawful, subject to legal exemptions.
• Right to restriction of processing: request limitation of processing under certain conditions.
• Right to data portability: receive your data in a structured, commonly used format and transmit it to another controller.
• Right to object: oppose processing based on legitimate interests or for direct marketing.
• Right to withdraw consent: withdraw consent at any time for processing based on consent.
• Right to lodge a complaint: file a complaint with the applicable supervisory authority if you believe your rights are violated.

Security measures

Spinmacho maintains appropriate technical and organizational safeguards to protect personal data from unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest.
• Strict access controls and authentication procedures.
• Regular security assessments and audits.
• Ongoing staff training on data protection and security practices.

Your responsibilities

Users must safeguard account credentials, use secure devices, and promptly report suspicious activity or notice of compromise.

Third‑party links

The Platform may contain links to external sites or services not operated by Spinmacho. We are not responsible for the privacy practices of such third parties, and you should review their policies directly.

Children’s privacy

Our Services are not intended for individuals under the age of 21. Spinmacho does not knowingly collect personal data from individuals under this age. If we become aware that we have collected data from a person under 21, we will take steps to delete it promptly.

International users

If you access the Platform from outside the jurisdiction in which Spinmacho operates, your data may be transferred to Spinmacho facilities and to jurisdictions with different data protection laws. You acknowledge and consent to such transfers where permitted by law.

Automated decision‑making and profiling

We may use automated decision‑making or profiling for fraud prevention and compliance purposes. You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects. You may request human intervention or express your view on such processing.

Marketing communications

We may use personal data to send marketing communications with your consent or where permitted by applicable law. You can update marketing preferences or opt out at any time through your account settings or by using the opt‑out options provided in communications.

Changes to this Privacy Policy

Spinmacho may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. We will provide notice of material changes on the Platform or via in‑app communications where feasible. The effective date of the current policy is indicated at the top of the document.

Data protection supervisory authority

You may lodge a complaint with the applicable data protection supervisory authority if you believe your rights under applicable data protection laws have been violated.

How to contact us

For questions, requests, or to exercise your rights under this Privacy Policy, please use Spinmacho's in‑platform contact tools. If you prefer, you may request to speak with our designated data protection officer through the same channels.

Conclusion

Your privacy is important to Spinmacho. We are committed to handling your personal data in a manner that is lawful, fair, and transparent.