Spin Games Privacy Policy – How We Protect Your Data

Spin Games is committed to protecting the privacy and personal data of all players who use its platform. We recognise that when you create an account and place bets with us, you are trusting us with information about yourself — your identity, your financial transactions, and your activity on the platform. We take that responsibility seriously.

This Privacy Policy is written to be clear and understandable. We have deliberately avoided dense legal language wherever possible so that Pakistani players can read and understand exactly what happens to their personal data when they use Spin Games. If anything in this document is unclear, please contact us at support@spingames.best and we will explain it in plain terms.

This policy applies to all personal data collected through spingames.best, including through account registration, deposit and withdrawal transactions, customer support interactions, promotional participation, and general use of the platform. It covers data collected both online and through any offline interactions you may have with Spin Games support staff.

Spin Games operates the online betting and gaming platform at spingames.best. In the context of this Privacy Policy, Spin Games is the data controller — meaning we determine the purposes and means by which personal data is processed.

If you have any questions about this Privacy Policy, your personal data, or how to exercise your data rights, the primary point of contact is:

• Platform: spingames.best
• Email: support@spingames.best
• Subject line for data requests: "Data Privacy Request – [your registered name]"

Spin Games processes player data from Pakistan. All data requests and communications regarding your personal information should be directed to the email address above. We aim to respond to all data-related enquiries within 30 calendar days.

Spin Games collects several categories of personal data from players. The following table summarises what we collect, how we collect it, and why:

We do not collect sensitive data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data. We do not collect data from social media profiles unless you explicitly provide it during a support interaction.

Spin Games uses the personal data we collect for the following purposes:

• Account management: Creating and maintaining your player account, processing login authentication, managing account settings, and communicating essential account information such as security alerts and balance notifications.
• Identity and age verification: Confirming that you are who you say you are and that you meet the minimum age requirement of 18 years. Verification may be conducted at registration and at any point during the lifetime of your account.
• Payment processing: Processing deposits and withdrawals via your chosen payment method. We pass necessary information to our payment processors but do not store raw financial credentials on our own servers beyond what is needed for transaction reference purposes.
• Bet settlement and account balance management: Recording and settling bets, crediting and debiting your account balance, and maintaining a transaction history accessible to you within your account.
• Fraud prevention and anti-money-laundering: Monitoring account activity for patterns consistent with fraudulent behaviour, collusion, bonus abuse, or money laundering. We are required by applicable regulations to report suspicious transactions to relevant authorities.
• Responsible Gaming monitoring: Tracking betting patterns to identify behaviour that may be consistent with problem gambling and to apply protective measures where appropriate, including contact from our Responsible Gaming team.
• Customer support: Responding to queries, resolving disputes, and maintaining records of communications to improve service quality and for reference in future interactions.
• Platform improvement: Using anonymised and aggregated data to understand how players use the platform, identify technical issues, and develop new features and products that better serve Pakistani players.
• Legal compliance: Meeting our obligations under applicable laws and regulations, including retention of financial records, cooperation with law enforcement requests, and compliance with anti-money-laundering requirements.
• Marketing (where opted in): Sending you promotional offers, bonus notifications, and other marketing communications where you have explicitly opted in to receive them. See Section 12 for full details on marketing and how to opt out.

Spin Games processes personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — operating your account, processing bets, handling deposits and withdrawals, and providing customer support. Without this processing, we cannot provide the service.
• Legal obligation: Processing required to comply with applicable laws, including anti-money-laundering regulations, age verification requirements, and financial record-keeping obligations.
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, security monitoring, platform improvement, and responsible gambling monitoring — where these interests are not overridden by your rights.
• Consent: Processing based on your explicit consent, specifically for marketing communications and analytics cookies. You may withdraw consent at any time without affecting any other aspect of your account.

Spin Games does not sell your personal data. We share it only in the following specific circumstances:

• Payment processors: We share necessary financial and identity data with payment processors (including mobile wallet providers such as Easypaisa, JazzCash, and NayaPay, and card payment networks) to process deposits and withdrawals. These processors are contractually bound to use your data only for payment processing and to maintain appropriate security standards.
• Identity verification providers: We may share identity documents with third-party verification services to confirm your identity and age. These providers process your data under strict data processing agreements and do not retain it beyond the verification purpose.
• Fraud prevention and security services: We share behavioural and technical data with fraud detection partners to identify and prevent fraudulent account activity. Shared data is anonymised or pseudonymised where possible.
• Legal and regulatory authorities: Where required by applicable law, regulation, court order, or law enforcement request, we are obligated to share relevant data with Pakistani governmental or regulatory bodies. We will notify you of such disclosures where legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, or sale of the Spin Games business, player data may be transferred to the acquiring entity. You will be notified in advance of any such transfer and your rights will be maintained.
• Responsible Gaming partners: In certain circumstances — specifically where a player has requested self-exclusion — we may share necessary information with responsible gambling organisations or schemes to give effect to that request.

All third parties with whom we share your data are required to handle it in accordance with applicable data protection standards and are prohibited from using it for any purpose beyond the specified service they are providing to Spin Games.

Spin Games retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active account data: Retained for the full duration of your account being open plus 5 years after account closure, in line with standard financial record-keeping obligations.
• Transaction and bet history: Retained for 7 years from the date of each transaction, as required for financial compliance and audit purposes.
• Identity verification documents: Retained for 5 years after account closure, or longer if required by regulatory or legal obligations.
• Customer support communications: Retained for 3 years from the date of the communication, unless related to an open dispute in which case they are retained until the dispute is fully resolved plus 2 years.
• Marketing preference records: Retained for the duration of your account plus 2 years to maintain an accurate record of consent and opt-out history.
• Technical and log data: Typically retained for 12 months and then deleted or anonymised, unless required for ongoing security investigations.

When the applicable retention period expires, Spin Games will securely delete or anonymise the data so that it can no longer be associated with any individual player.

Spin Games uses cookies and similar tracking technologies on the spingames.best platform. Cookies are small text files stored on your device that help the platform function correctly and allow us to understand how it is being used.

We use three categories of cookies:

• Essential cookies are required for the platform to function. They maintain your login session, remember items in your bet slip, and ensure security features work correctly. These cannot be disabled without breaking core platform functionality.
• Analytics cookies help us understand how players navigate the platform — which pages are visited most, how long players spend on different sections, and where technical issues occur. This data is used in aggregated, anonymised form to improve the platform. You can opt out of analytics cookies through your browser settings.
• Preference cookies remember your settings — such as your preferred language display, notification preferences, and display options — so you do not need to set them every time you visit. You can clear preference cookies through your browser settings though your preferences will reset.

Spin Games does not use third-party advertising cookies or allow advertising networks to place cookies on the platform. We do not use cross-site tracking technologies that follow you to other websites after you leave spingames.best.

As a Spin Games player, you have the following rights in relation to your personal data. To exercise any of these rights, contact us at support@spingames.best with the subject line "Data Rights Request".

Spin Games implements a comprehensive set of technical and organisational security measures to protect player data against unauthorised access, disclosure, alteration, and destruction:

• Transport Layer Security (TLS): All data transmitted between your browser and spingames.best is encrypted using TLS 1.2 or higher. Look for the padlock icon in your browser's address bar to confirm the secure connection.
• Password security: Player passwords are stored using industry-standard hashing — we cannot see your password and will never ask you to share it. Two-factor authentication is strongly recommended and available for all accounts.
• PCI-DSS compliance: Card payment processing is handled by processors certified to PCI-DSS standards. Raw card numbers are never stored on Spin Games servers.
• Access controls: Internal access to player data is restricted on a need-to-know basis. Staff who handle player data are trained in data protection obligations and are subject to confidentiality obligations.
• Fraud monitoring: Automated systems monitor account activity for signs of unauthorised access. Unusual login activity — such as access from a new device or location — may trigger additional verification requirements.
• Data breach response: In the event of a security breach that poses a risk to player data, Spin Games will notify affected players within 72 hours of becoming aware of the breach, with details of what happened and what steps are being taken.

While we implement rigorous security measures, no system is completely immune to risk. Players are strongly advised to use a unique, strong password for their Spin Games account and to never share their login credentials with any other person.

The Spin Games platform is intended exclusively for adults aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18.

If we become aware that we have collected personal data from an individual under 18, we will immediately close the relevant account, delete the associated personal data as far as legally permissible, and return any deposited funds net of any bonuses received.

Parents and guardians who believe that a minor has registered a Spin Games account should contact us immediately at support@spingames.best with the subject line "Under-Age Account" so we can investigate and take appropriate action promptly.

Spin Games recommends the use of parental control software on devices that may be used by minors to prevent access to gambling and betting websites. Our platform does not target or display advertising to individuals under 18.

Spin Games sends marketing communications — including bonus offers, promotional notifications, and platform updates — only to players who have explicitly opted in to receive them. Marketing communications are sent via:

• Email to your registered email address
• SMS to your registered mobile number
• In-platform notifications when you are logged in

You can opt out of marketing communications at any time through any of the following methods:

• Clicking the unsubscribe link in any marketing email
• Replying STOP to any marketing SMS
• Updating your communication preferences in your account settings
• Contacting support@spingames.best with the subject line "Marketing Opt-Out"

Players who have activated self-exclusion under the Responsible Gaming programme are automatically and immediately removed from all marketing lists. If you receive any marketing communication after activating self-exclusion, please contact us immediately so we can investigate and correct the issue.

Spin Games reviews and updates this Privacy Policy periodically to reflect changes in our data practices, legal requirements, or platform features. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page.
• Notify registered players by email or in-platform notification before the new policy takes effect, where the changes are material and could affect player rights or expectations.
• For significant changes to how we use your data, seek fresh consent where the processing relies on consent as its legal basis.

Your continued use of the Spin Games platform after the effective date of a revised Privacy Policy constitutes your acceptance of the revised terms. If you disagree with the revised policy, you should stop using the platform and may request account closure and return of your real-money balance under the previous policy terms within the notice period.

For any questions, concerns, or requests relating to this Privacy Policy or to your personal data, please contact Spin Games at:

• Email: support@spingames.best
• Subject line for privacy matters: "Privacy Policy Query" or "Data Rights Request – [your full name]"

We aim to respond to all privacy-related enquiries within 30 calendar days. For straightforward requests, we typically respond much faster than this.

If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter to the relevant data protection authority in Pakistan. Spin Games will cooperate fully with any regulatory investigation arising from a player complaint.

We encourage players to contact us directly in the first instance, as most privacy concerns can be resolved quickly through direct communication. Our support team is trained to handle data rights requests and will escalate to our data protection contact where necessary.