spinwi Privacy Policy

1 Who We Are

This Privacy Policy is issued by spinwi ("spinwi," "we," "us," or "our"), the operator of the online casino and sports betting platform available at spinwi.com. spinwi acts as the data controller in respect of all personal data collected through or in connection with the spinwi Platform.

spinwi serves players primarily based in Pakistan, including major cities such as Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, and Peshawar. This Privacy Policy applies to all individuals who access, browse, register on, or use any feature of the spinwi Platform, regardless of the device or method of access.

If you have any questions about how spinwi handles your personal data, please contact our data protection team at [email protected] before proceeding. We are happy to address any concerns before you create your account.

2 Personal Data We Collect

spinwi collects the following categories of personal data from players and prospective players:

Identity & Registration Data

• Full legal name as it appears on your Pakistani CNIC
• Date of birth (to verify the 21+ age requirement)
• Pakistani CNIC number (both sides of the card where required for KYC)
• City of residence within Pakistan
• Account username and hashed password

Contact Data

• Email address
• Mobile number (including JazzCash or EasyPaisa-registered numbers)

Financial & Transaction Data

• Deposit and withdrawal transaction records in PKR
• Payment method identifiers (e.g., JazzCash wallet number, EasyPaisa mobile number, bank account name and IBAN for HBL, UBL, or Meezan Bank transfers)
• Transaction timestamps, amounts, and reference numbers

Gaming & Behavioural Data

• Game history, bet records, and wagering patterns across all spinwi products including casino, cricket betting, slots, and fishing games
• Session duration, frequency of play, and responsible gaming tool usage
• Bonus and promotional offer redemptions

Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser information
• Session logs, access timestamps, and platform navigation data

3 How We Collect Your Data

spinwi collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion
• Automatically — through cookies, session tracking, server logs, and device fingerprinting technologies when you access and navigate the spinwi Platform
• From third-party KYC providers — identity verification data returned by our KYC partners when processing your CNIC and liveness check
• From payment processors — transaction confirmation data received from JazzCash, EasyPaisa, Raast/1LINK, HBL, UBL, or Meezan Bank when processing deposits or withdrawals
• From fraud and AML screening services — risk scores and watchlist screening results received from our anti-money laundering compliance partners

spinwi does not collect personal data from social media platforms or unaffiliated advertising networks. We do not purchase marketing lists or data profiles from third-party data brokers.

4 How We Use Your Personal Data

spinwi uses the personal data we collect for the following specific purposes:

spinwi does not use your personal data for automated individual decision-making that produces legal or similarly significant effects, except where required for AML or fraud prevention purposes — in which case you have the right to request human review of any automated decision.

5 Legal Basis for Processing

spinwi processes your personal data on the following legal bases:

• Contract performance — processing necessary to create and manage your account, provide gaming services, and process payments is required to fulfil our contractual obligations to you under the spinwi Terms & Conditions.
• Legal obligation — KYC verification, AML screening, age verification, and certain record-keeping activities are required by applicable law and regulatory obligations.
• Legitimate interests — fraud prevention, platform security monitoring, responsible gaming oversight, and aggregate analytics are carried out on the basis of spinwi's legitimate business interests, balanced against your privacy rights.
• Consent — where spinwi sends you optional marketing communications or uses non-essential cookies, we rely on your freely given, specific, and informed consent, which you may withdraw at any time.

6 Data Sharing & Disclosure

spinwi does not sell, rent, or trade your personal data. We share your data only with the following categories of recipients, and only to the extent necessary for each stated purpose:

• KYC & identity verification providers — to process CNIC-based identity and age verification
• Payment processors — JazzCash, EasyPaisa, Raast/1LINK infrastructure, HBL, UBL, and Meezan Bank, to facilitate PKR deposits and withdrawals
• AML and fraud screening services — to screen transactions and account activity against applicable watchlists and risk models
• Cloud infrastructure and hosting providers — to store platform data securely on servers subject to appropriate data protection agreements
• Customer support tools — to enable our support team to access relevant account information when responding to your queries
• Regulatory and law enforcement authorities — where spinwi is required by law, court order, or regulatory direction to disclose personal data

All third parties with whom spinwi shares personal data are contractually required to maintain appropriate security standards and to use the data only for the specific purpose for which it was shared. spinwi does not permit third-party processors to use your data for their own marketing or commercial purposes.

7 International Data Transfers

Some of spinwi's data processing partners — including cloud infrastructure providers and KYC verification services — may operate servers or processing facilities outside of Pakistan. Where personal data is transferred internationally, spinwi ensures that appropriate safeguards are in place, including:

• Data processing agreements incorporating standard contractual clauses or equivalent international data transfer mechanisms
• Requirements for recipient jurisdictions or processors to maintain security standards equivalent to or exceeding those applicable in Pakistan
• Regular review of international data transfer arrangements to ensure ongoing compliance

By creating a spinwi account and submitting your personal data, you acknowledge that your data may be transferred, stored, and processed in countries outside Pakistan as described in this section.

8 Data Retention

spinwi retains your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. The following general retention periods apply:

• Active account data — retained for the lifetime of your spinwi account
• KYC and identity documents — retained for a minimum of five (5) years following account closure, in compliance with applicable AML regulations
• Financial transaction records — retained for a minimum of five (5) years following the date of each transaction
• Customer support correspondence — retained for three (3) years following resolution of the relevant enquiry
• Technical and access logs — retained for twelve (12) months on a rolling basis
• Marketing consent records — retained for the duration of your consent and for one (1) year following withdrawal of consent

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents identification of the individual.

9 Cookies & Tracking Technologies

spinwi uses the following categories of cookies and similar technologies on the Platform:

• Strictly necessary cookies — required for the Platform to function, including session management, authentication, and security features. These cannot be disabled.
• Functional cookies — remember your preferences such as language settings, preferred payment method, and responsible gaming limits.
• Analytics cookies — collect aggregate, anonymised data about how players navigate and interact with the Platform, used solely to improve the spinwi user experience. No individual-level profiling is conducted.

spinwi does not use advertising cookies, retargeting pixels, or any cross-site tracking technologies. You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect Platform functionality.

10 Your Data Rights

As a spinwi player, you have the following rights in respect of your personal data held by spinwi:

• Right of access — you may request a copy of all personal data that spinwi holds about you, free of charge, within 30 calendar days of your request.
• Right of rectification — you may request correction of any inaccurate or incomplete personal data. Note that changes to KYC-verified identity data require re-verification.
• Right to erasure — you may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to spinwi's legal retention obligations.
• Right to restriction — you may request that spinwi restrict the processing of your personal data in certain circumstances, such as while a dispute is under review.
• Right to data portability — you may request a machine-readable export of personal data you have provided to spinwi.
• Right to object — you may object to processing based on spinwi's legitimate interests, including direct marketing communications.
• Rights related to automated processing — you have the right to request human review of any automated decision that significantly affects you.

To exercise any of the above rights, please contact the spinwi data protection team at [email protected] with the subject line "Data Rights Request." We will acknowledge your request within 5 business days and fulfil it within 30 calendar days, or notify you if an extension is required.

11 Children's Privacy

The spinwi Platform is intended exclusively for adults aged 21 and over. spinwi does not knowingly collect, process, or store personal data relating to individuals under the age of 21. Age verification is conducted as part of the KYC process for all registered accounts.

If spinwi becomes aware that personal data has been collected from an individual under the age of 21, that account will be immediately suspended, all associated data will be securely deleted, and any funds held in the account will be returned to the source payment method after deduction of any applicable transaction costs.

If you believe that spinwi may have inadvertently collected data from a person under the age of 21, please contact [email protected] immediately.

12 Security Measures

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

• 256-bit TLS encryption for all data in transit between your device and spinwi's servers
• AES-256 encryption for sensitive personal data stored at rest, including CNIC numbers, payment identifiers, and account credentials
• Multi-factor authentication (MFA) options for player accounts
• Role-based access controls limiting spinwi staff access to personal data on a strict need-to-know basis
• Regular penetration testing and third-party security audits of the Platform's infrastructure
• 24/7 intrusion detection and anomalous access monitoring
• Formal data breach response procedures with defined notification timelines

While spinwi takes every reasonable precaution to protect your data, no transmission over the internet or electronic storage system can be guaranteed to be 100% secure. Players are encouraged to use strong, unique passwords for their spinwi account and to enable any available MFA features.

13 Third-Party Links

The spinwi Platform does not contain links to third-party websites or applications. All content and navigation within spinwi.com remains within the spinwi domain. This Privacy Policy therefore applies exclusively to data collected and processed by spinwi and does not extend to any external platforms, payment provider apps, or banking applications that you may access independently in connection with your spinwi transactions.

When you initiate a JazzCash, EasyPaisa, or bank transfer transaction, you will be interacting with those providers' own platforms and privacy policies. spinwi is not responsible for the privacy practices of third-party payment providers. We encourage you to review their respective privacy notices before completing any transaction.

14 Changes to This Privacy Policy

spinwi reserves the right to update or revise this Privacy Policy at any time. Where changes are material — for example, where we introduce a new category of data collection or a new third-party processor — we will notify registered players via email and/or an in-Platform notification at least 14 days before the changes take effect.

Minor updates, such as clarifications of existing practices or corrections of typographical errors, may be made without advance notice. The "Last Updated" date at the top of this page will reflect the date of the most recent revision.

Your continued use of the spinwi Platform following the effective date of any revised Privacy Policy constitutes your acknowledgement of the updated terms. If you do not agree with the revised Privacy Policy, you must cease using the Platform and may request account closure by contacting support.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or spinwi's handling of your personal data, please contact our data protection team using the details below:

• Email: [email protected]
• Subject Line: Privacy Policy Enquiry / Data Rights Request
• Response Time: We aim to respond to all privacy-related enquiries within 5 business days
• Full Resolution: Data rights requests are fulfilled within 30 calendar days of receipt

For general support queries unrelated to privacy, please use the Live Chat feature available 24/7 within the spinwi Platform, or visit our FAQ page for answers to the most common questions.