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Privacy Policy

This Privacy Policy explains how spins-bit.com ("spin-bit", "we", "our", or "us") collects, processes, and protects your personal data when you use our services. It applies to all players and website visitors interacting with spins-bit.com and its associated platforms. The effective date of this policy is 6 November 2025.

Who We Are

OBSERVE: Spin-bit is operated by Dama N.V., registered at Scharlooweg 39, Willemstad, Curaçao (Company Registration Number: 152125), holding E-gaming License 8048/JAZ2020-013 issued by Antillephone N.V. Our regional operations extend to New Zealand with additional payment processing by Friolion Limited (HE 419102, Cyprus).

  • Legal Address: Scharlooweg 39, Willemstad, Curaçao
  • Primary Website: spins-bit.com
  • Data Protection Officer (DPO) / Data Protection Department Contact:

Please direct all privacy-related inquiries and data protection requests to the contacts listed above.

What Personal Data We Collect

OBSERVE: We collect various categories of personal and technical data necessary for legal compliance, secure operations, and service improvement.

  • Personal Identification Data: Full name, date of birth, address, email, phone number, and identification documents for KYC/AML compliance.
  • Account & Payment Data: Usernames, account activity, payment methods, transaction history, withdrawal and deposit records.
  • Technical Data: IP addresses, device information, browser type, operating system, access times, and server logs.
  • Behavioral Data: Game and betting histories, clickstreams, time spent, and navigation patterns within spins-bit.com.
  • Cookies & Tracking: Session IDs, persistent cookies, third-party analytics and advertising cookies, similar tracking technologies.

We only collect information required for lawful operation, security, and optimal user experience.

Legal Basis for Processing

OBSERVE: Processing of personal data by spins-bit.com is grounded in applicable New Zealand privacy law (Privacy Act 2020), international regulatory standards, and lawful gaming operations.

  1. User Consent: We obtain your explicit consent for certain data processing activities, especially for marketing and non-essential cookies. You may withdraw consent at any time.
  2. Contract Fulfillment: Data processing is necessary to register and manage your account, process transactions, and provide gaming services as per our Terms and Conditions.
  3. Legitimate Interests: Includes fraud prevention, security monitoring, analytics, service improvement, and responsible gambling enforcement.
  4. Legal Obligations: Compliance with anti-money laundering (AML), counter-terrorist financing (CTF), KYC, financial reporting, and regulatory requirements under Curaçao and NZ law.

We assess and document the legal basis for each processing activity, ensuring transparency and compliance.

Purpose of Processing

OBSERVE: Data is processed solely for legitimate, clearly defined purposes.

  • Service Provision: To create and manage user accounts, confirm identity, process deposits and withdrawals, and enable participation in games.
  • Compliance: To meet statutory obligations, including KYC/AML checks and reporting duties.
  • Fraud Prevention & Security: Detecting suspicious activity, enforcing account security, and investigating breaches.
  • Analytics & Service Improvement: Monitoring usage patterns, improving website functionality, and optimizing user experience.
  • Marketing & Communications: Sending promotional offers, newsletters, and updates (with user consent), and managing opt-outs.

We only use your data for the above purposes, never for unauthorized or unlawful activities.

Disclosure & Sharing

OBSERVE: We may share your personal data with carefully selected third parties under strict legal and contractual controls.

  • Payment Partners: Payment processors and financial institutions receive necessary data to facilitate secure transactions.
  • Service Providers: IT, analytics, and hosting providers may access data for essential business operations under confidentiality agreements.
  • Regulatory Authorities: Disclosure to regulators, law enforcement, or government agencies as required by law (including NZ and Curaçao authorities).
  • Affiliates & Subsidiaries: Sharing with Friolion Limited (Cyprus) and other group entities for payment processing and support functions.
  • Advertising Networks: Third-party marketing partners (only with explicit user consent) for targeted advertising.

Data is never sold, and all third-party access is governed by data protection agreements.

International Transfers

OBSERVE: As spins-bit.com operates internationally, your data may be transferred to, and processed in, countries outside New Zealand, including Curaçao and Cyprus.

  1. Transfer Destinations: Data may be processed in Curaçao (registered office), Cyprus (payment processing), and other jurisdictions as required for service delivery.
  2. Protection Mechanisms:
    • Standard Contractual Clauses (SCCs) and equivalent safeguards for non-NZ transfers.
    • Data processing agreements with all third parties ensuring adequate security and privacy standards.
    • Continuous monitoring of international data protection developments to ensure compliance.

We take all reasonable steps to ensure that your data is afforded an adequate level of protection, regardless of processing location.

Data Retention

OBSERVE: We retain personal data only as long as necessary for the purposes outlined in this policy and to comply with legal and regulatory obligations.

  • Account & Transaction Data: Retained for a minimum of 5 years from the date of account closure or final transaction, in line with AML and regulatory requirements.
  • Marketing Data: Retained until you withdraw consent or unsubscribe, after which it is deleted within 30 days.
  • Technical & Behavioral Data: Typically deleted or anonymized within 36 months unless required for fraud investigations or regulatory reporting.
  • Deletion Criteria: Data is deleted when (i) retention period expires, (ii) data is no longer necessary, or (iii) upon verified user request (subject to legal limitations).

All deletion and retention actions are documented and regularly audited.

Your Rights

OBSERVE: In accordance with the New Zealand Privacy Act 2020 and international standards, you have the following rights regarding your personal data held by spins-bit.com.

  1. Access: Request a copy of your personal data held by us.
  2. Correction: Request correction of inaccurate or incomplete data.
  3. Deletion ("Right to be Forgotten"): Request deletion of your data where no longer necessary or where you withdraw consent, subject to regulatory retention obligations.
  4. Restriction: Request restriction of processing in certain circumstances (e.g., contesting accuracy, pending objection).
  5. Objection: Object to processing for direct marketing or where processing is based on legitimate interests.
  6. Data Portability: Request transmission of your personal data in a structured, commonly used, and machine-readable format.
  7. Withdrawal of Consent: Withdraw consent for marketing or non-essential processing at any time without detriment.

Procedures for Exercising Rights:

  • Submit requests via support@spins-bit.com or Live Chat.
  • We will acknowledge requests within 5 working days and respond substantively within 30 calendar days.
  • No fees apply unless requests are manifestly unfounded or excessive.
  • For unresolved matters, you may escalate to the NZ Office of the Privacy Commissioner (privacy.org.nz).

We uphold your rights in accordance with NZ law and recognized international data protection frameworks.

Cookies & Tracking Technologies

OBSERVE: spins-bit.com uses cookies and similar technologies to enhance user experience and ensure secure operations.

  • Session Cookies: Temporary cookies essential for site navigation and secure logins, deleted after your session ends.
  • Persistent Cookies: Remain on your device for a defined period to remember preferences and facilitate faster access.
  • Third-Party Cookies: Set by analytics (e.g., Google Analytics) and advertising partners for service improvement and tailored marketing, only with your explicit consent.

You can manage or disable cookies via your browser settings or the internal cookie consent panel on spins-bit.com. Disabling certain cookies may impact site functionality.

Data Security

OBSERVE: We implement robust technical and organizational measures to safeguard your personal data.

  1. Encryption: All data is encrypted in transit (TLS 1.2+) and at rest using industry-standard algorithms.
  2. Access Controls: Multi-factor authentication, role-based access, and strict staff access policies.
  3. Security Audits: Regular internal and external audits, vulnerability assessments, and penetration testing aligned with ISO 27001 and SOC 2 standards.
  4. Incident Response: Documented procedures for breach detection, response, and user notification, with prompt escalation to relevant authorities as required.
  5. Staff Training: Ongoing staff education on data protection, privacy, and secure handling of user data.

We continuously enhance our security posture to address emerging risks and regulatory developments.

Complaints & Contacts

OBSERVE: If you have concerns about your privacy or wish to make a complaint, you may contact our Data Protection Officer or use the channels below.

  1. Step 1: Submit your complaint via email or live chat with a detailed description of your concern.
  2. Step 2: We will acknowledge your complaint within 5 business days and provide a substantive response within 30 days.
  3. Step 3: If you are dissatisfied with our response, you have the right to escalate your complaint to the New Zealand Office of the Privacy Commissioner:

We are committed to resolving all privacy concerns promptly and transparently.

Updates

OBSERVE: This Privacy Policy may be updated to reflect regulatory changes, service enhancements, or security improvements.

  • Notification Methods: We will notify users of material changes by email, on-site banners, and account dashboard alerts.
  • Advance Notice: For significant changes, we will provide at least 30 days' advance notice before changes take effect.
  • User Options: You may object to changes or close your account if you disagree with updated terms.
  • Version Control: Last updated: 6 November 2025. A detailed changelog will be provided for all material amendments.

Continued use of spins-bit.com after updates constitutes acceptance of the revised Privacy Policy.