spinjili Privacy Policy

1. Introduction

spinjili ("spinjili," "we," "us," or "our") is committed to protecting the privacy and personal data of all users of the spinjili online gaming platform, accessible at spinjili.club. This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect your personal information when you visit our website, register an account, or use any of our services.

This Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. It also reflects our obligations under PAGCOR's regulatory framework for licensed online gaming operators and the Anti-Money Laundering Act of the Philippines (Republic Act No. 9160, as amended).

By registering a spinjili account or using our platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please do not use the spinjili platform.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, spinjili is the personal information controller responsible for your personal data collected through the spinjili platform. This means we determine the purposes and means of processing your personal information.

Our designated Data Protection Officer (DPO) oversees compliance with this Policy and applicable data privacy legislation. You may contact our DPO through the contact details provided in Section 16 of this Policy. All data privacy inquiries, complaints, and requests to exercise your rights under RA 10173 should be directed to our DPO.

3. Personal Data We Collect

spinjili collects the following categories of personal data from players and platform visitors:

3.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identification document.
• Date of birth (used to verify that you meet the 21-year minimum age requirement).
• Residential address in the Philippines.
• Email address and mobile phone number.
• Government-issued identification document details (e.g., Philippine passport number, driver's license number, SSS/UMID/PhilSys ID number).

3.2 Financial Data

• Payment method details, including GCash account number, PayMaya account number, or bank account details for BPI, BDO, or Metrobank.
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method used.
• Source of funds documentation where required by anti-money laundering regulations.

3.3 Gaming & Activity Data

• Game history, including games played, wagers placed, outcomes, and winnings.
• Bonus and promotion usage history.
• Responsible gaming tool settings, including deposit limits, loss limits, and self-exclusion records.
• Customer support interaction records, including chat transcripts and email correspondence.

3.4 Technical & Usage Data

• IP address and approximate geolocation data.
• Device type, operating system, and browser information.
• Pages visited, time spent on the platform, and navigation patterns.
• Cookie identifiers and similar tracking technology data (see Section 11).

4. How We Collect Your Data

spinjili collects your personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the spinjili platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from security partners; payment confirmation data from GCash, PayMaya, BPI, BDO, and Metrobank.
• Regulatory sources: Information received from PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine regulatory authorities in connection with our compliance obligations.

5. How We Use Your Personal Data

spinjili uses your personal data for the following purposes:

• To create and manage your spinjili player account.
• To verify your identity and age in compliance with PAGCOR requirements and Philippine law.
• To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank.
• To deliver the games, promotions, and other services available on the spinjili platform.
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities.
• To comply with our legal and regulatory obligations, including reporting requirements under the Anti-Money Laundering Act.
• To provide customer support and respond to your inquiries and complaints.
• To send you service-related communications, including account notifications, transaction confirmations, and security alerts.
• To send you marketing communications about spinjili promotions and new games, where you have consented to receive such communications.
• To improve the spinjili platform through analytics and user experience research.
• To enforce our Terms and Conditions and other platform policies.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, spinjili processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and service delivery.
• Legal obligation: Processing required to comply with applicable Philippine law, including KYC verification, anti-money laundering reporting, and PAGCOR regulatory requirements.
• Legitimate interests: Processing necessary for spinjili's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

spinjili does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank, to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party service providers engaged to assist with identity verification and document authentication.
• Fraud prevention and security partners: Service providers that assist spinjili in detecting and preventing fraud, money laundering, and other prohibited activities.
• IT and platform service providers: Cloud hosting, data storage, and software service providers engaged to support the operation of the spinjili platform, all of whom are bound by data processing agreements consistent with RA 10173.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law or regulatory directive.
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by spinjili in connection with our business operations, subject to confidentiality obligations.

All third parties with whom spinjili shares personal data are required to handle that data in accordance with applicable Philippine data privacy law and to implement appropriate technical and organizational security measures.

8. International Data Transfers

Where spinjili engages service providers located outside the Philippines (for example, cloud infrastructure providers), your personal data may be transferred to and processed in countries other than the Philippines. In such cases, spinjili ensures that appropriate safeguards are in place to protect your personal data, consistent with the requirements of the Data Privacy Act of 2012 and the rules of the National Privacy Commission. These safeguards may include contractual data processing agreements that impose data protection obligations equivalent to those applicable in the Philippines.

By using the spinjili platform, you acknowledge and consent to the transfer of your personal data to countries outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

9. Data Retention

spinjili retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulatory obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR requirements and anti-money laundering legislation.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• Gaming activity data: Retained for the duration of your account and for up to three (3) years following account closure.
• Customer support records: Retained for up to three (3) years from the date of the interaction.
• Technical and usage data: Retained for up to twelve (12) months from collection, unless required for longer periods for security or fraud investigation purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with spinjili's data disposal procedures.

10. Security Measures

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

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the spinjili platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Role-based access controls limiting access to personal data to authorized spinjili personnel on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the spinjili platform.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Staff training on data privacy obligations and information security best practices.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, spinjili will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-03.

11. Cookies & Tracking Technologies

spinjili uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit the spinjili website. We use the following categories of cookies:

• Strictly necessary cookies: Essential for the operation of the spinjili platform, including session management and security functions. These cookies cannot be disabled.
• Functional cookies: Used to remember your preferences and settings, such as your preferred language and display options.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the spinjili platform, helping us identify areas for improvement.
• Security cookies: Used to detect and prevent fraudulent activity, including bot detection and session integrity verification.

You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the spinjili platform. spinjili does not use third-party advertising or behavioral tracking cookies.

12. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by spinjili:

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 16. We will respond to all verified requests within thirty (30) days, as required by the Data Privacy Act of 2012. We may need to verify your identity before processing your request.

13. Minors & Age Restriction

The spinjili platform is strictly for individuals aged 21 years and above, in accordance with Philippine law and PAGCOR regulations governing casino-style online gaming. spinjili does not knowingly collect personal data from individuals under the age of 21.

If spinjili discovers that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and return any deposited funds at our discretion after deducting applicable processing fees. If you believe that a minor has registered a spinjili account, please contact our support team immediately.

14. Third-Party Links

The spinjili platform may contain links to third-party websites or services. This Privacy Policy applies solely to the spinjili platform and does not cover the data practices of any third-party websites. spinjili is not responsible for the privacy practices or content of any third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

15. Changes to This Privacy Policy

spinjili reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. Where changes are material, we will provide reasonable advance notice to registered players via email or a prominent notice on the spinjili platform before the updated Policy takes effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the spinjili platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you do not agree to the updated Policy, you must stop using the platform and may request account closure in accordance with our Terms and Conditions.

16. Contact Our Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or spinjili's data practices, please contact our Data Protection Officer:

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 its official government channels.