spinph2 Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") describes how spinph2 ("spinph2," "we," "us," or "our") collects, uses, discloses, stores, and protects the personal information of individuals ("you," "your," or "Player") who access or use the spinph2 website, mobile platform, games, and related services (collectively, the "Platform").

This Policy applies to all personal data processed by spinph2 in connection with the Platform, regardless of whether you are a registered player, a visitor browsing the spinph2 website, or a prospective player who has not yet completed registration.

By accessing or using the spinph2 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. This Policy should be read together with our Terms & Conditions.

2. Who We Are (Data Controller)

For the purposes of the Data Privacy Act of 2012, spinph2 is the personal information controller responsible for your personal data collected through the Platform. spinph2 determines the purposes and means of processing your personal information in connection with the provision of online casino and sports betting services in the Philippines.

If you have any questions about how spinph2 handles your personal data, or if you wish to exercise any of your rights under the DPA, please contact our Data Protection Officer (DPO) using the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

spinph2 collects the following categories of personal data in connection with the Platform:

spinph2 does not intentionally collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and regulatory compliance purposes. spinph2 does not collect information about your racial or ethnic origin, political opinions, religious beliefs, or health data except where required by law.

4. How We Collect Your Data

spinph2 collects your personal data through the following means:

• Direct interactions: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs. See Section 8 for more details on cookies.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from GCash, PayMaya, and banking partners; and publicly available information where relevant for compliance purposes.
• Regulatory sources: Information received from PAGCOR or other competent Philippine authorities in connection with our regulatory obligations.

5. How We Use Your Personal Data

spinph2 uses your personal data for the following purposes:

• To create, manage, and maintain your spinph2 account;
• To verify your identity and age (21+) in compliance with PAGCOR regulations and Philippine law;
• To process deposits, withdrawals, and other financial transactions, including GCash and bank transfers;
• To provide access to spinph2 games, promotions, and platform features;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities in compliance with the Anti-Money Laundering Act (AMLA);
• To provide customer support and respond to your enquiries and complaints;
• To send you service-related communications, including account notifications, security alerts, and transaction confirmations;
• To send you marketing communications about spinph2 promotions and offers, where you have consented to receive such communications;
• To personalise your gaming experience and improve the spinph2 Platform;
• To comply with our legal and regulatory obligations under Philippine law, including PAGCOR licensing requirements and the DPA;
• To enforce our Terms & Conditions and protect the rights and interests of spinph2 and other players.

6. Legal Bases for Processing

Under the Data Privacy Act of 2012, spinph2 processes your personal data on the following legal bases:

• Contractual necessity: Processing necessary to perform our contract with you (i.e., the spinph2 Terms & Conditions), including account management, game provision, and payment processing.
• Legal obligation: Processing necessary to comply with our legal and regulatory obligations, including PAGCOR licensing requirements, AMLA compliance, and KYC/identity verification obligations.
• Legitimate interests: Processing necessary for spinph2's legitimate interests, including fraud prevention, platform security, and improving our services, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications. You may withdraw your consent at any time by contacting spinph2 customer support.

7. Sharing Your Personal Data

spinph2 does not sell, rent, or trade your personal data. spinph2 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:

• Service providers: Third-party vendors who provide services on spinph2's behalf, including KYC and identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), IT infrastructure providers, customer support platforms, and fraud prevention services. These providers are contractually bound to process your data only on spinph2's instructions and in accordance with the DPA.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government authorities, where required by law or regulatory obligation.
• Law enforcement: Philippine law enforcement agencies, where spinph2 is legally required or permitted to disclose your information in connection with the investigation or prosecution of criminal offences.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of spinph2's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

spinph2 will not share your personal data with any third party for their own independent marketing purposes without your explicit consent.

8. Cookies and Tracking Technologies

spinph2 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and support security and fraud prevention measures. The following types of cookies may be used:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, authentication, and security features. These cookies cannot be disabled.
• Functional cookies: Used to remember your preferences and settings, such as language preferences and responsible gaming limits.
• Analytics cookies: Used to collect aggregated, anonymised data about how players use the Platform, helping spinph2 improve its services and user experience.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and other security threats on the Platform.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the spinph2 Platform. By continuing to use the Platform, you consent to spinph2's use of cookies as described in this section.

9. Data Security

spinph2 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the spinph2 Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security assessments and vulnerability testing of the Platform;
• Two-factor authentication options for player accounts;
• Secure data centres with physical access controls.

While spinph2 takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. spinph2 cannot guarantee absolute security but is committed to promptly addressing any security incidents that may occur.

10. Data Retention

spinph2 retains your personal data for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your spinph2 account and for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and AMLA obligations.
• Financial and transaction data: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• Gaming and wagering data: Retained for the duration of your account and for a minimum of three (3) years following account closure.
• Customer support communications: Retained for a minimum of two (2) years from the date of the communication.
• Technical and log data: Retained for up to twelve (12) months, unless required for longer periods for security or legal purposes.

When your personal data is no longer required, spinph2 will securely delete or anonymise it in accordance with applicable data protection standards.

11. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by spinph2:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as described in this Policy.
• Right of access: The right to request a copy of the personal data spinph2 holds about you, and information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data spinph2 holds about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to spinph2's legal and regulatory retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on spinph2's legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe spinph2 has not handled your personal data in accordance with the DPA.

To exercise any of these rights, please contact spinph2's Data Protection Officer using the contact details in Section 15. spinph2 will respond to all data subject requests within the timeframes required by the DPA. Please note that certain rights may be subject to limitations where spinph2 is required to retain or process your data to comply with legal obligations.

12. Children's Privacy

The spinph2 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations and Philippine law. spinph2 does not knowingly collect personal data from individuals under the age of 21. If spinph2 becomes aware that it has inadvertently collected personal data from a person under 21, it will promptly delete such data and close the associated account.

If you believe that spinph2 may have collected personal data from a minor, please contact us immediately using the details in Section 15.

13. Cross-Border Data Transfers

In certain circumstances, spinph2 may transfer your personal data to service providers or partners located outside the Philippines, for example in connection with cloud hosting, KYC verification, or fraud prevention services. Where such transfers occur, spinph2 ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses consistent with the requirements of the Philippine Data Privacy Act and the standards set by the National Privacy Commission.

spinph2 will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards and, where required, obtaining your consent.

14. Changes to This Privacy Policy

spinph2 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. The date of the most recent revision will be indicated at the top of this page.

Where changes are material, spinph2 will provide reasonable advance notice to registered players via email or a prominent notice on the Platform. Your continued use of the spinph2 Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the Platform and close your account.

15. How to Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or spinph2's handling of your personal data, please contact our Data Protection Officer:

Data Protection Officer – spinph2
Email: [email protected]

Please include your registered username and a clear description of your query or request. spinph2 aims to acknowledge all data privacy enquiries within 72 hours and to resolve them within the timeframes required by the Data Privacy Act of 2012.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with spinph2's response to your data privacy concern.