A Confidential Statement Regarding Your SpinYoo Casino Data

Our primary goals in collecting and using your personal information are to fulfil our service promises to you and to ensure that we meet all applicable legal and regulatory requirements. To begin gambling with us, for instance, you must first create an account. When you sign up for an account, we'll need to know some basic information about you, such as your name, username, contact info, birthday, and address. We will also use the information you provide to verify your age and identity, as well as your ability to bet, in order to ensure that you are who you claim to be.

Making sure you are gaming responsibly and providing you with the greatest experience possible are our top priorities.

1. Greetings Out There!

Your privacy and confidentiality are of the utmost importance to us. Regardless of the country or region from which you use our website, this Privacy and Cookie Notice (the Notice) will enlighten you on our practices regarding the handling of personal data collected during your visit, as well as your rights to privacy and the safeguards provided by law. From time to time, we may make changes to this Notice. If we make any substantial changes to this Notice, we will let you know so that you may make the necessary adjustments before the new Notice takes effect on the website. It is our recommendation that you revisit this Notice periodically.

The "Terms of Use" (as used in our website's Terms and Conditions and any other documents referenced within) should be read in conjunction with this Notice.

We prioritise maintaining accurate and up-to-date personal data about you. While you are a customer of ours, please let us know if any of your personal information changes.

2.  Responsible for Data

In accordance with our position as a controller (or data controller) under data protection legislation, we will handle and retain the personal information you have given us in a safe manner. According to the law, "controller" is the entity that decides how to handle certain pieces of personal information.

White Hat Gaming Limited (WHG) runs the SpinYoo brand, which is owned by Yellow Day Marketing Limited (the Partner).

When it comes to your personal information, the two businesses are sharing data controller responsibilities. The Partner is liable for the purposes pertaining to the promotion of the services, whereas WHG is liable for the purposes pertaining to the supply of the gaming services.

Your personal information will be transferred to the Partner as the only data controller at the end of the joint service offering.

Please contact our designated Data Protection Officer (DPO) at privacy@spinyoo.com if you have any questions or concerns about how we handle your personal data. We will do our best to address your enquiry.

On the other hand, you can go to idpc.org.mt/file-a-complaint to report any issues with our handling of your concern or our compliance with our legal obligations to the Office of the Information and Data Protection Commissioner (IDPC), the Lead Supervisory Authority that oversees our company in matters pertaining to data protection.

3. Data That We Gather About You

Any piece of information that may be used to identify a specific person is considered personal data. Data that has had its identities erased (anonymous data) is not part of it. Among the many types of personally identifiable information that we may gather, use, retain, and transmit to third parties are:

• A person's gender, date of birth, marital status, job title, username, and last name are all examples of identity data.

• The term "Contact Data" refers to the details that users supply when they sign up for our website, subscribe to our services (including product promotions), publish content, or request more services. This data may include their billing address, email address, and phone number.

• When you join a contest or competition, make a complaint or query to our Customer Support, report an issue with our Website, or contact us for any other reason, we may keep records of your communication, which is called communication Data. For the sake of training and quality management, as well as to facilitate the rapid settlement of enquiries, we reserve the right to record your telephone calls.

• Data pertaining to your financial situation and bank accounts is known as financial data.

• Included in the "Transaction Data" are specifics on the goods and services you've bought from us, as well as information regarding payments made to and from you.

• Included in the category of "Technical Data" are details on the device you are using to access this website, such as the operating system, platform, browser type and version, time zone settings, location, and internet protocol (IP) address.

• Your username, password, and the results of any bets you've placed are all part of your profile data.

• Some examples of Usage Data include details on your navigation around our site.

• As you can see in the "My Account" area, "Marketing and Communications Data" contains information about the ways you would want to receive marketing materials from us and our partners, as well as any other communication preferences you may have.

Aggregated Data, including demographic and statistical information, is also something we gather, utilise, and share. Even though it may be produced from your personal data, Aggregated Data is not legally considered personal data as it does not expose your identify in any way, either directly or indirectly.

In addition, we may gather information on your health and any relevant criminal convictions or crimes as well as other specific types of personal data. Unless we are required by law, a regulator, or your explicit consent to do so, we will not routinely gather this information; instead, we will only do so in very specific situations.

4. Neglecting to Provide Personal Information

Failure to give requested personal data may prevent us from performing the contract we have or are attempting to enter into with you (such as providing you with the services via our website) in situations where such data is required by law or under the terms of our agreement with you. We will inform you if we are required to terminate a service or product you have with us in this instance.

5. Information About you is Gathered in What Ways?

There are a variety of ways that we get information about you and from you, including:

• Personal encounters. By contacting with us or filling out forms, you may provide us with personal data. Personal information gathered via activities like as creating an account, placing bets or wagering monies on games through our website, requesting advertisements to be delivered to you, entering a competition, survey, or providing feedback is included in this category.

• Technologies or interactions that are automated. Automatic data collection about your device, browsing activities, and habits (including personal data) may occur when you use our website. Cookies, server logs, and other technologies allow us to gather this personally identifiable information. To find out more, check out our cookie section down below.

• Third parties or publically accessible sources. For the processing objectives of crime prevention and detection and responsible gaming, as mentioned in section 6 below, we may supplement the personal data we possess about you with data from third parties and public sources.

You may streamline the sign-up process by using a third-party authentication service like Bank ID, Google Sign-In, Trustly, or any other comparable Pay n Play solution. Personal data (Registration and Contact Data) will be immediately added to your profile from the third-party source to assist your registration if this method is utilised, once you provide us the authorisation to access and the required information during sign-up.

6. The Ways in Which We Use Your Data to Work

We will not handle your personal data unless we can demonstrate a legitimate reason to do so, in line with data protection regulations. Regarding your personal data, these grounds include: (i) the necessity to fulfil our contractual obligations to you; (ii) compliance with applicable laws or regulations; (iii) your consent; and (iv) our legitimate interests in processing your data, so long as these interests do not infringe upon your rights, freedoms, or interests.

For the following reasons and on these basis, we shall handle your personal data:

As may be required to fulfil a contractual obligation or to comply with applicable laws and regulations, or as may be required in the course of providing you with additional services.

Information that does not personally identify you but, when combined with other data, does not allow us to contact you may be utilised by us. Data pertaining to gameplay, technological aspects, and analytics might all be part of this. Therefore, we do not know who the user is from whom the aggregated data was obtained. We utilise this data for a variety of reasons, including but not limited to advertising, service enhancement, fraud prevention, and site analytics. We may collect this data on our own or with the assistance of third-party service providers.

We may process your personal data directly or hire other members of our group or service providers (processors) to do so in cases where we have given you explicit permission to do so; these third parties must also comply with this Notice and use your personal data only for the purposes described above.

If we need to know your financial situation to provide a good service or meet our responsible gambling requirements, we may share your personal information with third parties like TransUnion. For more details on how this business stores and utilises your personal information.

7. Transferring Data

Transferring your information to countries outside of the EU may be required due to our worldwide operations. We will take measures, such as implementing standard contractual clauses in accordance with European Commission Decision (EU) 2021/914 of 4 June 2021, to guarantee that your personal data is adequately protected in countries where data protection and other laws are not as extensive as those in the European Union.

8. Marketing at Spin Yoo

Your personal information, including name, home address, email, phone number, etc., may be used by us or our third party subcontractors to send you promotional materials about our website and other products, services, websites, and applications from: (i) other companies in our Group; (ii) White Label Brands; or (iii) Group's business partners and affiliates (collectively referred to as the "Marketing Affiliates").

Additionally, we may share and disclose information with our marketing affiliates so that you might get various marketing offers that we or our affiliates think would be relevant to you. Various marketing strategies, including direct email, postal, SMS, and telephone marketing, may be used by our Marketing Affiliates using this information.

If you have not already agreed to receive marketing materials, we will not send them to you. Contacting us using the unsubscribe link in any of our emails gives you the option to stop receiving marketing messages from us or our partners at any moment. Keep in mind that we may keep sending you service-related updates and alerts even after you unsubscribe from our marketing email list.

To get ad measurement services and to provide you material about our websites, respectively, we may employ Google and Facebook Ads services. In order to provide you this material, we may divulge certain details to Facebook. Click here to learn more about Facebook ads. When you use our website, you're giving Facebook and us permission to use your data for targeted advertisements. You may change your Facebook settings at the aforementioned link if you'd rather not get such ads.

9. Computerised Decision-making, Tracking, and Profiling

Our computer systems keep track of all wagers, games, and account activities. In order to meet our licencing and regulatory requirements and to help us improve the service we provide to you, we also routinely monitor all transactions as they happen.

Section 9.1. Responsible gaming purposes. Our legal responsibility to comply with licencing and regulatory requirements requires us to keep tabs on our players, reach out to those who may be struggling with or at risk of developing gambling issues, and provide them with the assistance they need. meet this responsibility, we have developed guidelines for identifying potential gambling addicts and taking appropriate action based on past player behaviour data, including Responsible Gaming Data, Transaction and Usage Data, and Other Communication Data.

Although our system seldom makes decisions without human input, there are rare cases where it locks users' accounts or applies limitations without their knowledge. If you would want to challenge a decision or request human review or intervention, you may reach out to us at privacy@spinyoo.com whenever you like.

Section 9.2. Combating the practice of money laundering. Furthermore, we must comply with the law and keep an eye on its participants in order to detect any questionable behaviour. The algorithm proposes a degree of risk based on player behaviour data, namely Transaction and Usage Data.

Humans must intervene in order for decisions based on these forecasts to be made.

10. Safety Measures

In order to keep your personal information safe against unauthorised access, processing, loss, destruction, or damage, we have put safeguards in place. The sensitivity of the data we gather and keep dictates the kind of protections we put in place. We prioritise the security of your personal data, which includes your registration details and any financial information you provide us, such as debit or credit card details.

Our secure pages use, at a minimum, TLS v1.2 encryption. You are obligated to maintain the secrecy of any password that we may have provided you with, or that you may have selected, in order to access certain areas of our websites.

While sent over the internet, any personally identifiable information will always be encrypted. When you submit sensitive information on our protected sites, it is immediately encrypted using SSL, a specific protocol. Afterwards, our server decrypts the data using a secret key. As a result, all of your sensitive information, including financial details like bank account numbers, is encrypted into a code that requires a secret key or password to decipher. When you first visit any protected page on the Website, you will get a warning message if your browser is set up correctly. This is only to let you know that the website takes security of your information seriously.

Data transfer via the internet is not foolproof, unfortunately. While we take precautions to safeguard your information, we cannot guarantee the safety of any personally identifiable information you may provide online. You understand that there are risks associated with accessing the internet and agree that we are not liable for any security breach unless we have violated our duties under data protection laws. To ensure the security of your personal information, we ask that you refrain from sending us any emails that include sensitive details, such as financial account numbers.

10. Holding on

Your personal information will be stored for the duration of your service usage and no longer than five years thereafter, unless there is a legal or regulatory need that states otherwise. Please be informed that while we will make every effort to delete personal data as soon as it is no longer needed, there are certain situations in which we may be obligated by law or have good faith beliefs that it is essential to retain the data for business or legal purposes.

11. What we May Want From You, Your Legal Rights, and The Expenses Involved

Requests: Data protection rules provide you certain rights with respect to your personal data in certain situations. Please email privacy@spinyoo.com or write to our Data Protection Representative in the UK at the address given in section 2 if you would want to exercise any of the rights listed below. But keep in mind that not every right is absolute.

There will be no cost to you in accessing your personal data or exercising any of your other rights. On the other hand, if your request is obviously unreasonable, exorbitant, or recurrent, we reserve the right to demand a fair cost. On the other hand, in these conditions, we may decline to fulfil your request.

In order to verify your identity and provide you access to your personal data (or to exercise any of your other rights), we may ask for some information from you. To prevent unauthorised parties from gaining access to your personal information, we have implemented this security safeguard. In order to expedite our response, we may possibly reach out to you for further information on your request.

Responding to valid enquiries is our priority, and we aim to do so within one month. If your request is really complicated or if you have made several requests, it may take us more than a month to complete them. If this occurs, we will inform you and provide you with updates.

Protected rights:

• Fill out a "data subject access request" form to get a copy of your personal information. You have the right to see and verify the accuracy of your personal data held by us by requesting a copy of this data.

• You have the right to access and rectify your personal information that we have on file. This gives you the option to amend any incorrect or incomplete information we have on file for you, albeit we may have to check the new information you provide us to make sure it's right.

• Pursue the deletion of all records pertaining to you. If you no longer have a legitimate interest in us processing your personal information, you may request that we erase it. In cases where you have successfully exercised your right to object to processing, where we may have processed your information illegally, or where we are compelled to erase your personal data to comply with local legislation, you also have the right to ask us to delete or remove your data. Be advised that there are some legal or regulatory reasons why we may not always be able to grant your request for erasure. If this is the case, we will inform you of these reasons when you make your request.

• "Object to processing" means that you do not want your personal data used in a way that we believe violates your rights and freedoms, even when we are relying on a legitimate interest to do so (or the legitimate interest of a third party). Additionally, in cases where we are using your data for direct marketing, you may ask us to stop. If we can prove that processing your information is necessary to protect our legitimate interests, we will do it even if it means violating your privacy.

• Require human review or involvement in the event that you disagree with an automated choice we've made.

• Ask to have your personal information limited in its processing. Here are some situations where you can ask us to suspend processing of your personal data: (a) if you want us to make sure the data is accurate; (b) if our use of the data is illegal but you don't want it erased; (c) if you need the data even after we no longer need it because you have legal claims that need it; or (d) if you've objected to our use of the data but we need to find out if there are overriding legitimate grounds to continue using it.

• Ask to have your personal information sent either to you or another party of your choosing. We regret to inform you that this service is not accessible at this time and that we are required to do so by this Notice.

• If we are processing your personal data based on your permission, you have the right to withdraw it at any moment. What this means, therefore, is that processing done before you withdraw your permission will still be legal. Certain goods or services may no longer be available to you if you choose to withdraw your permission. When you withdraw your permission, we will let you know whether this is true.

12. Leave the Group

We may use the contact information you provided as a player to periodically notify you about improvements to our products, upcoming events, promotional materials, and competitions, among other things related to the services you have used or subscribed to. If you would want to not receive these messages, you have the option to do so. You may also choose to receive crucial update notifications while disabling all general communications. For your convenience, we will provide unsubscribe information in every message we send. We may email you about things that are considered critical to the service, therefore you won't be able to unsubscribe from such messages.

13. Data Collected by Third Parties

It should be noted that regardless of whether they are accessible, downloaded, or otherwise provided via the Website, this Notice is not applicable to any third-party websites, services, or apps. Before you provide any personal information to any third parties, make sure you understand their privacy policies thoroughly.

14. Deal Involving Companies

In the case of a corporate transaction involving any company within the Group, such as the sale of a large portion of our business, merger, reorganisation, bankruptcy, consolidation, or selling or transferring an asset, we may be required to disclose certain information. The rights and responsibilities outlined in this Notice shall be assumed by the acquiring business or transferee in the case of the aforementioned.

16. Publication for Purposes of Law

At times, we may be compelled to reveal certain categories of personal information by means of a legal process, a court order, or other official directive. Here are some examples of when this may happen:

• When it comes to the fair administration of justice or when we need to provide a legal defence.

17. Words About Cookies and Pixels Policy

"Cookies" are little text files that websites and apps save to your device when you visit their sites or use their apps. With the help of the cookie, the server may gather data from the user's browser. Some of the cookie kinds that we may utilise are:

Essential cookies are those that a website cannot function properly without them. There would be some functionality issues with the Website if cookies weren't used. When you sign in, for instance, a session is generated that grants you access to the site and its games;

ANALYTICAL COOKIES: To keep tabs on how well the site is doing and what features users like, we use analytical cookies. Using the data collected by these cookies, we may improve our goods for customers and pinpoint which parts of our site may require repair. Among the many online analytics tools offered by Google, Inc., Google Analytics is one that we are now using. To assist us assess how gamers use our Website, Google Analytics employs cookies. Additional third-party companies' analytical cookies are also used by us;

The term "persistent cookie" refers to a kind of cookie that remains on your computer even after you exit your browser. To personalise your experience on our site, show you relevant ads and marketing messages based on your past actions, and remember which language you prefer when you come again, we utilise these types of cookies.

Functional cookies improve your experience on our website by remembering your preferences. This has several potential uses, such as saving your username or marking a message as read so you don't have to go back and read it;

SESSION COOKIES: The server stores information about the user's page activities in session cookies, allowing users to seamlessly resume their previous actions on the server's pages.

For the purpose of recognising you, tracking your activities, and improving your usage and experience of the Website, we use a variety of cookies on this site. To round out our service offerings, we rely on a variety of third-party vendors, some of whom may also place cookies on our site. Services like this allow us to do things like measure how well our marketing efforts and the website itself are doing, as well as keep tabs on what you do when you visit the site, so we can make it better for you.

Cookies allow us and third parties to gather information about your use of the Website and to display advertisements on other websites based on that data. Here at www.aboutads.info/choices, you have the option to examine the cookies used for such purposes on this Website and to opt out of the gathering and use of your information for such targeted advertising.

Some individuals find it creepy that websites may keep information about them on their devices, especially when third parties utilise this information without their knowledge. In most cases, this is completely innocuous; nonetheless, there are situations in which you would prefer not to view interest-based advertisements. You may choose to disable all cookies or only the ones you want; but, if you do this, you should be prepared to lose some of the features that make that website unique. The majority of web browsers are set to accept cookies automatically. But you can change your browser settings to limit or disable cookies if you want to.

Point B: Pixels

In addition, we monitor the number of impressions that ads get and the duration of each platform visit using pixel-based monitoring. We also utilise this data for retargeting and to optimise our marketing efforts by measuring conversions. Our advertising and marketing partners may get this information (which does not include any personally identifiable information) from us. In section 8, we detail our marketing strategies in detail. You provide your approval for the Website and its services to use pixels and cookies on your device as described in this Notice when you access and use them.

Released: 5.0

Current date: 16-10-2024