spintime Privacy Policy

spintime is an online gaming and casino platform operated for the benefit of Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Quezon City, Makati, and beyond. For the purposes of this Privacy Policy, spintime is the data controller responsible for the personal information collected through the spintime platform.

spintime is committed to protecting the privacy and personal data of all users in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its implementing rules and regulations, as well as any other applicable data protection legislation.

If you have any questions about how spintime handles your personal data, or if you wish to exercise any of your data rights, please contact the spintime Data Privacy Officer using the contact details provided in Section 14 of this Policy.

spintime collects personal data that is necessary to provide you with a safe, compliant, and fully functional gaming experience. The categories of personal data we collect include the following:

spintime collects personal data through the following means:

• Direct interactions: Data you provide when registering a spintime account, completing KYC verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the spintime platform, including through cookies, web beacons, server logs, and similar tracking technologies. See Section 7 for more details.
• Third-party sources: Data received from identity verification providers, payment processors (such as GCash and PayMaya), fraud prevention services, and regulatory databases where permitted by applicable law.
• Public sources: Publicly available information used to verify your identity or to comply with anti-money laundering obligations, such as sanctions lists and politically exposed persons (PEP) databases.

spintime uses your personal data for the following purposes:

• To create, manage, and maintain your spintime player account.
• To verify your identity and age (21+ requirement) in compliance with applicable gaming regulations.
• To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• To detect, investigate, and prevent fraud, money laundering, and other illegal or prohibited activities on the spintime platform.
• To comply with legal and regulatory obligations, including reporting requirements under Philippine anti-money laundering laws.
• To provide customer support and resolve disputes or complaints.
• To send you transactional communications related to your spintime account, such as deposit confirmations, withdrawal notifications, and security alerts.
• To send you marketing communications about spintime promotions, bonuses, and new games, where you have consented to receive such communications.
• To monitor your gaming activity for responsible gaming purposes and to apply any self-imposed limits or restrictions on your account.
• To improve the spintime platform, personalise your gaming experience, and conduct internal analytics and research.
• To enforce the spintime Terms and Conditions and other platform policies.

spintime processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable regulations:

• Contractual necessity: Processing required to perform the contract between you and spintime, including account registration, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC/AML obligations, age verification requirements, and regulatory reporting duties.
• Legitimate interests: Processing carried out for spintime's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications and certain responsible gaming assessments. You may withdraw your consent at any time.

spintime 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, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML service providers used to verify your identity, age, and source of funds.
• Game providers: Licensed third-party game studios and live casino operators whose games are available on the spintime platform. These providers may receive limited technical data necessary to deliver their games.
• Regulatory authorities: Philippine government agencies, including PAGCOR and the Anti-Money Laundering Council (AMLC), where disclosure is required by law or regulatory instruction.
• Law enforcement: Police, courts, and other law enforcement authorities where spintime is legally required or permitted to disclose personal data.
• IT and security service providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on spintime's behalf under strict data processing agreements.
• Professional advisers: Lawyers, auditors, and accountants where necessary for spintime's legal and compliance obligations.

All third parties with whom spintime shares personal data are required to maintain appropriate technical and organisational security measures and to process your data only for the specified purpose and in accordance with spintime's instructions.

The spintime platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and collect analytical data about platform usage. The types of cookies used by spintime include:

• Strictly necessary cookies: Essential for the spintime platform to function correctly, including session management and security features. These cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to personalise your spintime experience.
• Analytical cookies: Used to collect anonymised data about how players use the spintime platform, helping us identify areas for improvement. This data does not identify you personally.
• Security cookies: Used to detect and prevent fraudulent activity, protect your spintime account, and maintain platform integrity.

spintime retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general rule, spintime retains player account data for a minimum of five (5) years following the closure or termination of your spintime account. This retention period reflects spintime's obligations under Philippine anti-money laundering legislation, which requires gaming operators to retain transaction records for a minimum of five years.

Specific retention periods for different categories of data are as follows:

• Identity and verification documents: 5 years from account closure.
• Financial transaction records: 5 years from the date of the transaction.
• Customer support communications: 3 years from the date of the communication.
• Technical and usage logs: 12 months from the date of collection, unless required for an ongoing investigation.
• Marketing consent records: Until you withdraw consent, plus 1 year thereafter for compliance purposes.

Upon expiry of the applicable retention period, spintime will securely delete or anonymise your personal data in accordance with its data disposal procedures.

spintime implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the spintime platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Role-based access controls limiting spintime staff access to personal data on a strict need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments of the spintime platform.
• Multi-factor authentication options for spintime player accounts.
• Continuous monitoring of the spintime platform for suspicious activity and potential security incidents.
• Staff training on data protection and information security best practices.

While spintime takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for keeping your spintime login credentials confidential and for notifying spintime immediately if you suspect any unauthorised access to your account.

Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights with respect to your personal data held by spintime:

• Right to be informed: You have the right to be informed about how spintime collects and uses your personal data, as set out in this Privacy Policy.
• Right of access: You have the right to request a copy of the personal data spintime holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request that spintime correct any inaccurate or incomplete personal data held about you.
• Right to erasure: You have the right to request that spintime delete your personal data where it is no longer necessary for the purpose for which it was collected, subject to spintime's legal retention obligations.
• Right to object: You have the right to object to spintime's processing of your personal data for direct marketing purposes at any time.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that spintime transmit that data to another controller where technically feasible.
• Right to withdraw consent: Where spintime processes your personal data on the basis of your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe spintime has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact the spintime Data Privacy Officer using the contact details in Section 14. spintime will respond to all data rights requests within 30 calendar days of receipt. In complex cases, this period may be extended by a further 30 days, and spintime will notify you of any such extension.

The spintime platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. spintime does not knowingly collect personal data from individuals under the age of 21.

If spintime becomes aware that personal data has been collected from a person under the age of 21, spintime will take immediate steps to delete that data and close the associated account. If you believe that spintime may have inadvertently collected personal data from a minor, please contact the spintime Data Privacy Officer immediately using the contact details in Section 14.

spintime primarily processes and stores personal data within the Philippines. However, some of spintime's third-party service providers, including cloud infrastructure providers and game studios, may be located in other countries. Where personal data is transferred outside the Philippines, spintime ensures that appropriate safeguards are in place to protect your data, including:

• Transferring data only to countries that have been assessed as providing an adequate level of data protection.
• Implementing standard contractual clauses or other approved transfer mechanisms with recipient organisations.
• Conducting due diligence on all third-party recipients to ensure they maintain appropriate data protection standards.

By using the spintime platform, you acknowledge and consent to the transfer of your personal data to third-party service providers located outside the Philippines, subject to the safeguards described above.

spintime reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When we make material changes to this Policy, we will notify you by posting a prominent notice on the spintime platform and, where appropriate, by sending an email to your registered email address.

The updated Privacy Policy will take effect on the date specified in the notice. Your continued use of the spintime platform after the effective date of any update constitutes your acceptance of the revised Policy. We encourage you to review this Privacy Policy periodically to stay informed about how spintime protects your personal data.

The current version of this Privacy Policy was last updated on January 1, 2026. Previous versions of this Policy are available upon request from the spintime Data Privacy Officer.

If you have any questions, concerns, or complaints about this Privacy Policy or about how spintime handles your personal data, please contact the spintime Data Privacy Officer:

If you are not satisfied with spintime's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory body responsible for administering and implementing the Data Privacy Act of 2012.

For more information about your rights under the Data Privacy Act of 2012, or to file a complaint with the NPC, please visit the official NPC website or contact the NPC directly. spintime encourages players to contact us first so that we have the opportunity to address your concern before escalating to the NPC.