Privacy Policy

Last Updated: October 12, 2025

1. Introduction

Spinovate Oy ("we," "us," "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and protect information when you use our social casino platform.

This policy complies with the EU General Data Protection Regulation (GDPR) and Finnish data protection laws.

2. Data Controller

Spinovate Oy
PL 105
00101 Helsinki, Finland
Email: privacy@spinovate.com

3. Information We Collect

3.1 Information You Provide

  • Age verification confirmation (18+ status)
  • Contact information (if you reach out to us)
  • Cookie and consent preferences

3.2 Information Automatically Collected

  • Device and browser information
  • IP address and geographic location
  • Game play data and virtual credit balances
  • Usage patterns and interactions with the platform

3.3 Cookies and Similar Technologies

We use cookies and local storage to enhance your experience. For detailed information, please see our Cookie Policy.

4. How We Use Your Information

We process your personal data for the following purposes:

  • Service Provision: To operate and maintain the platform, including saving game progress
  • Age Verification: To ensure compliance with age restrictions
  • Analytics: To understand usage patterns and improve the platform (with your consent)
  • Communication: To respond to your inquiries and provide support
  • Legal Compliance: To comply with Finnish and EU legal obligations
  • Security: To detect and prevent fraud, abuse, and security incidents

5. Legal Basis for Processing

We process your personal data based on:

  • Consent: For non-essential cookies and analytics
  • Legitimate Interests: For platform security, fraud prevention, and service improvement
  • Legal Obligation: For age verification and compliance with Finnish law

6. Data Sharing and Disclosure

We do not sell your personal data. We may share data with:

  • Service Providers: Third-party processors who assist with analytics and hosting (only after you provide consent for non-essential services)
  • Legal Authorities: When required by law or to protect our rights

All third-party processors are bound by data protection agreements and process data only according to our instructions.

7. International Data Transfers

Your data is primarily stored and processed within the European Economic Area (EEA). If data is transferred outside the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses.

8. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy:

  • Age verification: Stored locally; retained until you clear browser data
  • Cookie preferences: Retained for 12 months or until changed
  • Game progress: Stored locally; retained indefinitely unless cleared
  • Contact inquiries: Retained for 3 years after resolution

9. Your Rights Under GDPR

You have the following rights regarding your personal data:

  • Right of Access: Request a copy of your personal data
  • Right to Rectification: Correct inaccurate or incomplete data
  • Right to Erasure: Request deletion of your personal data
  • Right to Restriction: Limit how we process your data
  • Right to Data Portability: Receive your data in a structured format
  • Right to Object: Object to processing based on legitimate interests
  • Right to Withdraw Consent: Withdraw consent for analytics and marketing cookies at any time

To exercise these rights, contact us at privacy@spinovate.com.

10. Right to Lodge a Complaint

You have the right to lodge a complaint with the Finnish Data Protection Ombudsman if you believe we have violated your data protection rights:

Office of the Data Protection Ombudsman
Website: tietosuoja.fi/en/home

11. Security Measures

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or destruction. However, no method of transmission over the internet is 100% secure.

12. Children's Privacy

Spinovate is not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors. If we discover that we have inadvertently collected such data, we will delete it promptly.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date. Continued use of the service after changes constitutes acceptance.

14. Contact Us

For questions, concerns, or to exercise your rights, please contact:

Spinovate Oy
PL 105
00101 Helsinki, Finland
Email: privacy@spinovate.com