Privacy Policy

Last Update: 26.09.2025
Version: 1.0

Definitions

Personal Data refers to any information concerning an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, identification number, location data, online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Processing at Spin Pirate Casino refers to any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Profiling refers to any form of automated processing of personal data consisting of using personal data to evaluate certain personal aspects relating to a natural person, particularly to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements;

Controller refers to the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or specific criteria for its nomination may be provided for by Union or Member State law;

Processor refers to a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Recipient refers to a natural or legal person, public authority, agency or another body, to which personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with applicable data protection rules according to the purposes of processing;

Third party refers to a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;

Consent of the data subject refers to any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or clear affirmative action, signifies agreement to processing of personal data relating to him or her;

Personal data breach refers to a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;

Group of undertakings refers to a controlling undertaking and its controlled undertakings;

Supervisory authority refers to an independent public authority established by a Member State pursuant to Article 51 GDPR;

General

This notice together with the General Terms and Conditions available on the site sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By registering a Player Account with SpinPirate Casino you confirm your acceptance of this Privacy Policy. Please be advised that if you do not accept the terms outlined in this Privacy Policy and choose not to provide the necessary personal information, your access to certain features and services offered on this website may be limited.

Please note that this Privacy Policy constitutes an agreement between you and SpinPirate Casino. It is important to note that this Privacy Policy may be periodically updated and revised. While we will make reasonable efforts to inform you of any significant changes, we recommend that you review this Privacy Policy regularly to stay informed of our current practices regarding the collection, use, and protection of your personal information. Your continued use of SpinPirate Casino and/or its services will constitute your acceptance of the Privacy Policy.

SpinPirate Casino values your integrity and privacy immensely and is committed to managing all your personal data in a transparent, fair and lawful manner. This privacy policy (together with the Terms & Conditions and Cookie Policy) sets out the basis upon which SpinPirate Casino collects, stores, and uses your personal data when you visit our website, as well as what your rights are, and how the law protects those rights according to the Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 on the protection of natural persons with regard to processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)

This website is solely intended for persons over the age of 18, and we do not knowingly collect data relating to persons under such age. If it becomes apparent to us that we have collected personal data relating to persons under the age of 18, due to reasons relating to abuse of our website, we do our best to ensure that such data is handled in accordance with applicable law.

About Us

As a data controller, we have a legal obligation under gambling regulations to process personal data from players in order to allow them to participate in games and provide them with ancillary services.

When we mention “Company”, “Group”, “we”, “us” or “our” in this privacy notice, we are referring to SpinPirate Interactive Ltd.

We take your privacy seriously. For this reason we have appointed a data protection officer (“DPO”) whose responsibility is to oversee that the company is compliant with its legal obligations in respect of processing your personal data, and who is your contact point for any questions relating to this Privacy Policy. Should you have any queries about this policy, including any request to exercise your legal rights, and complaints about violation of your rights please contact our DPO using email [email protected].

Contact Us

You may always contact us in regards to this Policy should you wish to:

Confirm the accuracy of personal information we have collected about you; Enquire about our use of your personal information; Prohibit future use of your data for direct marketing purposes; Receive a copy of personal information stored about you; Unless you have elected not to receive promotional materials, we may use your Personal Information, including your email address and phone number, to send you marketing communications regarding products, services and promotions. This may include information about products and services from our business partners, such as casino game providers.

Whenever you decide to stop receiving such marketing and advertising material, you may opt out of this by signing up, in your Player Account settings or by contacting our customer support at [email protected] and/or livechat.

Update or rectify any information that you have provided us (in such cases you shall provide any evidence we may reasonably require to effect such changes). Note it is illegal to provide us with false information about you and it is your responsibility to ensure that we are always updated with your correct data.

To fulfill your requests in accordance with this privacy policy, you can use the following means of communication:

• using email [email protected]
• using Live Chat Live Chat SpinPirate Casino
• using the email of the data protection officer [email protected]

Please note that in some cases emails may end up in spam or may not reach the addressee at all for technical reasons.

If your request is not answered within 10 days we strongly recommend you to contact us again for clarification using alternative methods of communication.

Information We Collect

Information you provide us. It includes any of the information that you provide to us when filling in forms on our account registration pages, as well as any other data that you further submit via SpinPirate Casino or email. It includes information you provide when you register to use our site, subscribe to our service, make deposits, bets or withdrawals on our site, participate in chat rooms, accept bonuses or other promotions available on our site, any due diligence documentation you share with us, including source of wealth questionnaire and supporting documentation, and when you report a problem or make a complaint with us. The information you give us may include your name, username, address, date of birth, country of residence and nationality, identification number, e-mail address, and phone number, financial and credit card information, personal description, proof of identification, proof of address, proof of funds and photograph.

Technical information, that includes the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about your visit, including full Uniform Resource Locators (URL), Information received from cookies. Please refer to our Cookie Notice for further details on types of cookies in use.

Gameplay information. Games you played and duration on each game and page, page interaction information,

Analytics information. In some cases we may collect information about your use of Services, such as applications’ usage, log files, user activity (e.g. pages viewed, amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of Services.

Information we receive from other sources. This is information we receive about you if you use any of our websites or services operated by the Group. In the event that you use accounts on multiple sites operated by the Group we may collate information about you generated from each site in one data repository. Such data is important to us for statistical purposes, but also particularly relevant within the context of our Anti-Money Laundering and Responsible Gambling responsibilities as arising out of law.

During the course of delivering services to you, we are also working closely with third party data processors, joint or/and independent data controllers (including, for example, business partners, sub-contractors in technical, payment and delivery services as well as for delivery of marketing information (such as CRM Tool Providers, Email Marketing Partners, SMS Providers, Direct Mail Distributors and Outbound Call providers,) advertising networks and affiliate networks, analytics providers, due diligence intelligence companies, search information providers, credit reference agencies). This category includes information we receive from our Publishers, Advertisers and other Partners that we work with to help us deliver ads and personalized content to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some Advertisers or other third-party ad platforms choose to share with us. Data processors process personal data according to our written instructions and their activities will be limited to those that are needed from them to assist us deliver the service to you.

Categories of Data We Store About You

Personal data means any information about an individual from which that person can be identified directly or indirectly. It does not include data where identity has been removed (anonymous data).

The personal data collected and processed on you can be grouped into the following categories:

Identity Data includes first name, middle name, last name, email, username or similar identifier, date of birth, gender.

Contact Data includes residential address, email address, telephone numbers other available means of communication

Financial Data includes details of your salary and wealth, details of sources of funds used to deposit with us, as well as bank account, payment card or payment account details, including information contained within any bank statements, scans of documents, confirming your income and similar documentation collected for KYC Purposes.

Transaction Data includes details about deposits and withdrawals, wagering and other details of games you have played on our sites.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on devices you use to access this website.

Usage Data includes information about how you use our website, products and services, online identifier to login (email), password (encrypted), games played, login and logout times, duration of play, bonuses and promotions claimed, responsible gaming information, limits and history and AML classification.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Special Categories of Personal Data. In the event that you provide us with such information yourself and In fulfillment of our legal obligations, we must also collect some Special Categories of Personal Data about you such as

Information related to responsible gaming that can be considered as medical data Information about your racial or ethnic origin, which can be obtained from documents you uploaded.

How We Can Use Your Information

Information you give to us:

to carry out our obligations arising from terms and conditions entered into between you and us and to provide you with gaming services that you request from us, to accept your deposits and process your withdrawals, to carry out fraud management processes, to answer to any query or complaint that you may have as well as other ancillary matters related to main services we are providing to you; provided that you have granted consent to contact you with marketing information from the Group, to provide you with information about our services, bonuses schemes and promotions and information about products and promotions of related sites operated by the Group or its brands; to provide customized advertising on the site based on your interactions with the site or your Usage Data; to notify you about changes to our service; to meet obligations arising from Anti-Money Laundering Legislation and rules and regulations thereunder and all other laws that we may be subject to from time to time.

Information we collect about you:

to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. Such information will typically be collected through use of Cookies. For more information on Cookies please refer to our Cookie Notice which also provides guidance on the manner in which Cookies may be disabled; to contact you with marketing information, to provide you with information about services, bonuses schemes and promotions and information about products and promotions, present or future, offered by the brand you registered with based on legitimate interest or with marketing information about brand partners in case you have expressed your consent to receive such materials; to carry out fraud management and risk management activities, including assigning a risk profile or risk status to your account; to assess your behavior and patterns through the site which will be used to help build a detailed customer profile on you, on different subject matters, including but not limited to: A register of bonus abusers may be created by the company and persons on this list may be excluded from any future promotions or even blocked from using services of SpinPirate Casino. This includes analysis of other types of fraud and fraudulent behavior. We will also screen and monitor your transactions and behavior for reasons of responsible gambling, ensuring that your interaction with us remains fun and entertainment and not dangerous to you. We may assign a Responsible Gambling score to your account based on information we collect and responsible gambling questionnaire, which may at times be provided to you to fill. As a result of our assessment you may be tagged as a ‘Problem Gambler’ or vulnerable to risks of gambling addiction. As part of our commitment to prevent money laundering and terrorist financing, we may also analyze your personal data and compare it to third party data sources, build an AML profile on you and risk score your account based on information you have provided to us and information we have collected about you. We shall also keep a register of all high risk customers from an Anti-Money Laundering perspective. Please note that for these purposes we partially use profiling with the end decision performed by humans, however logic behind profiling and information about it cannot be revealed since it would enable customers to bypass these control mechanisms aimed at protection of Our business and compliance with legal obligations.

to improve our site to ensure that content is presented in most effective manner for you and for your computer; to allow you to participate in interactive features of our service, when you choose to do so; as part of our efforts to keep our site safe and secure; to measure or understand effectiveness of advertising we serve to you and others, and to deliver relevant promotions to you; to make suggestions and recommendations to you about our products. We also may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat combined data as personal data which will be used in accordance with this privacy notice.

Information we receive from other sources:

We will combine this information with information you give to us and information we collect about you. We will use this information and combined information for purposes set out above (depending on types of information we receive). Other sources include third party service providers of age verification tools, identity or address verification services, regulators or entities that keep central databases of problem gamblers, providers of PEP and Sanction searches, and other similar providers who we may contract with from time to time. We may also receive information about you collected from other sites operated by the Group which helps us deliver a better service to you or to keep away bonus abusers, problem gamblers from our services.

Lawful Basis for Processing of Personal Data

We have set out below, in table format, a description of all ways we plan to use your personal data, and which of legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. In regards to processing personal data based on a legal obligation, we refer to provisions of Anti-Money Laundering Directive (EU) 2015/849 of European Parliament and Council, and UK Gambling Act 2005.

Sharing of Data

Due to the nature of our service, in order to process your data as explained above in this Privacy Policy, we may need to share your personal data with a number of trusted third parties. These third parties include:

Any member of the Group which requires access to your personal information in order to provide services you request. Data we receive and collect on you maybe shared with any member of the Group and such data may be used by them for fraud and bonus abuse prevention, AML and Responsible Gaming Reasons in fulfillment of the Group’s legal obligations and legitimate business interests;

To all members of the Group for purposes of such other group entities to contact you with information on their products and services, provided that you have consented to receive direct marketing related to other sites operated by the Group.

—Employees of SpinPirate Casino, more specifically Data Protection Officer, Money Laundering Officer, Payments & Anti-Fraud analysts, Customer Support agents, Customer Retention team members, VIP player managers as well as other selected employees, shall also have access to your Personal Information for purpose of executing their duties and providing you with assistance as well as to provide services you requested

Our employees who have access to, or are associated with processing of player’s personal information, have signed confidentiality agreements (NDA) to respect confidential nature of player’s information.

Game providers – sometimes our game providers would require access to select data attributes (such as username and IP address, for instance), in order to provide us with games you play on our website. To check their privacy notice please visit relevant website of Game provider;

When you play casino games developed by NetEnt, NetEnt’s Privacy Policy also applies. This policy can be found on NetEnt Privacy Policy page.

Payments providers and related service providers – similarly, we may share some of your personal data with payment providers you use to make and receive payments on our website. To check their privacy notice please visit relevant website of Payment provider you’ve used;

If SpinPirate Casino needs to share data with its payment processors to facilitate payment transactions in accordance with their privacy policies. (In particular, most banking card transactions are processed by Trustly whose Trustly privacy policy applies to such transactions. Transactions may also be processed by Bambora or Paysafe);

Marketing partners—where you give us your consent to send you marketing and promotions, we may share your contact details (such as email address or mailing address) with our marketing partners who take care of sending out all our marketing material to you including promotional emails and SMS, direct mail, and at times to makes calls to you.

Governmental or regulatory authorities—We may, if necessary or authorized by law, provide your personal data to law enforcement agencies, governmental or regulatory organizations, courts or other public authorities. We may dispute such demands when we believe that requests are disproportionate, vague or lack proper authority, but we do not promise to challenge every demand;

Client communication software – we use third-party software to help us communicate with you. This software enables us to send you emails and chat with you on live chat whenever you have queries;

AML and fraud verification tools, suppliers of age and identity verification tools and other suppliers that can verify Know Your Client (KYC) information generally– we may use third party software to conduct certain AML and fraud verification checks which are required to satisfy our legal obligations in this regard.

In addition to the above, we may also release personal data if we acquire any new businesses. Should SpinPirate Casino undergo any changes to its structure such as a merger, acquisition by another company or partial acquisition, it is most likely that our customers’ personal data will be included within sale or transfer. We will, as part of our Policy, inform our players by email prior to affecting such transfer of personal data.

Selected third parties, under a data processing agreement with us that ensures safeguard of your personal information, including:

• with our lawyers, advisors, consultants who we may engage from time to time to manage risks, obtain professional advice, or to establish and defend our legal claims, whether in court or in an out-of-court procedure. This may require to gain access to personal information;
• with governmental bodies, regulatory authorities who register problem gamblers or for any other responsible gaming purpose.
• with any company, governmental body, regulatory authority that maintains a register or database having objective of preventing crime, money laundering or terrorist and proliferation financing.

We always ensure that any third party having access to your personal data is bound to respect security of your personal data, and to process it in a lawful manner at all times and in compliance with our Privacy Policy and strict codes of conduct. We do not allow any third-party service providers to use your personal data for their own purposes. Processing by such third parties (also known as “Data Processors”) is solely carried out for specific purposes and in accordance with our instructions as Data Controller and on our behalf, and such third parties may only use your personal data to extent to which we ourselves are entitled. Furthermore, in all cases, we strive to ensure that we do not share more data than is necessary to be shared for service providers to carry out processing activities in accordance with our instructions.