Effective from: 15.11.2018 Last updated: 15.04.2020
The website www.spinia.com ("Casino", "Website", “Company”, "We", "Us", "Our") is owned and operated by N1 Interactive Ltd, a company incorporated under the laws of Malta with registration number C 81457 and registered address at 206, Wisely House, Old Bakery Street, Valletta VLT1451, Malta. Spinia casino is licensed and regulated by the Malta Gaming Authority under the licences: MGA/B2C/394/2017 (issued on 01/08/2018).
2. INFORMATION WE COLLECT
The Personal Information which we may request to use and process shall include, without limitation:
- Any of the information that you provide to us when filling in the forms on our account registration pages, as well as any other data that you further submit via the Website or email (e.g. first and last name, date of birth, email address, phone number);
- Correspondence made with us via the Website, email, web chat or through other means of communication;
- All Player Account transaction history, whether this takes place via the Website(s) or via other means of communication;
- Website logins and their details, including traffic data, GeoIP location data, browser/device data, weblogs, activity logs and other traffic information recorded in our system;
- Documents and proofs reasonably requested by us to verify your account, to process deposits or withdrawals and to conduct anti-fraud checks (on our own initiative or as required by applicable legislation). Such proofs may include passport scans, payment slips, bank statements, etc.
- Survey participations or any other customer assessments that we may carry out from time to time.
3. HOW WE USE YOUR INFORMATION
We process the Personal Information we collect from you in order to deliver our services. In particular, we will use your data for the following purposes:
- Processing your bets and transactions. This includes your use of credit card and online payment systems;
- Providing you with gaming and other ancillary services that you seek from our Website;
- Rendering customer support, such as assistance with setting up and managing your account;
- Identifying and performing the necessary verification checks;
- Providing registered players with information about our promotional offers, or providing promotional information from our selected business partners, associates and affiliates (only if players specifically consented to receiving such marketing material);
- Complying with legal responsibilities, including complying with anti-money laundering (AML) and combating the financing of terrorism (CFT) laws;
- Monitoring and investigating transactions for the purposes of preventing fraud, terms abuse, money laundering and other illegal or irregular gaming activities;
- Analysing customer trends through market study assessments (participation in surveys is not obligatory and you can always choose not to take part);
- Conducting research and statistical analysis of aggregated data.
4. MARKETING COMMUNICATION
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 in your Player Account settings or by contacting our customer support at firstname.lastname@example.org. Additionally, note that by accepting any contest prize or winnings from us, you consent to the use of your name and/or nickname for advertising and promotional purposes without additional compensation, except where prohibited by law.
5. OBTAINING PERSONAL INFORMATION
We shall not collect any Personal Information about you without your knowledge. We may, however, automatically collect certain data about you where you would have provided such information through the use of our services and through your interactions with us.
We may also lawfully receive certain Personal Information from online vendors and service providers, such as fraud prevention companies. In addition, we retain the right to engage the services of third-party providers to render technical support, so as to process your online transactions and source gaming content.
6. DATA RECIPIENTS
We may pass information that you have given us to other entities within our group of companies and to our business partners. These companies include our parent companies, their parent companies and all of the subsidiaries of these respective companies, as well as other companies with whom we carry out business and hold necessary agreements. Data processing of your information may be undertaken by N1 Interactive Ltd or by another company in the group of companies, which may use a third party to fulfill such data processing needs.
Employees of the Company, 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 the purpose of executing their duties and providing you with assistance.
Our employees who have access to, or are associated with the processing of the player’s personal information, have signed confidentiality agreements to respect the confidential nature of the player’s information pursuant to applicable gaming, data protection and privacy laws.
It may be necessary for us or our service providers to transfer your personal data to countries outside of the European Union (EU), the European Free Trade Association (EFTA) regions, and the European Economic Area (EEA) in order to provide you with our services or engage with service providers and data processors. However, In accordance with the General Data Protection Regulation (GDPR), we are obliged to ensuring the protection of your personal data during these transfers.
This transfer may be necessary in order to provide you with our services such as:
a) Processing your bets and payment transactions;
b) Providing you with gaming and other ancillary services that you seek from our Website;
c) Identifying and performing the necessary verification checks;
By using our services and accessing our website, you accept possible transfer of your personal data to third countries and the implementation of these safeguards. If you have any questions or concerns regarding these transfers, please do not hesitate to reach out to us.
7. RELEASING DATA TO THIRD PARTIES
We do not sell or rent your personal data to third parties.
We may disclose your personal information if required by law, regulation, or other legal subpoena or warrant. We may also disclose your personal information to a regulatory or law enforcement agency if we believe it to be necessary to protect the legitimate interests of the Company, its customers or any third party.
We use third-party data processors to process limited personal data on our behalf. Such service providers support the Website, especially relating to hosting and operating the websites, marketing, analytics, improving the websites, and sending email newsletters. We shall ensure that the transfer of the Personal Data to the recipient is compliant with applicable Data Protection Legislation and that the same obligations are imposed on the processor as is imposed on us under the respective Services Agreement.
Please note our content may link to third party websites to provide relevant references. We are not responsible for such external content, which may contain separate privacy policies and data processing disclosures.
8. DATA RETENTION
As stated under our Terms and Conditions both, you and the Casino can decide to have your Player Account closed at any time. Following closure of your account, we will retain your personal data on record for as long as required by law. This data shall only be used should it be required by competent authorities in cases of enquiries regarding financial and fiscal records, fraud, money laundering or investigations into any other illegal activity.
You are to note that due to anti-money laundering regulations in licensed gaming jurisdictions in the European Union, we are obliged to retain personal data of players submitted during registration and any data passed on during the operative period of a Player Account for a minimum of five years from last player transaction or account closure. Therefore, requests for erasure prior to the lapse of this period cannot be entertained.
We may also keep anonymized derivatives of your data to improve our content and marketing communications where no automated decision making is involved.
9. SECURITY OF YOUR DATA
We hereby acknowledge that in collecting and processing your Personal Information for the purposes of managing your Player Account, we are bound by strict legal provisions on the protection of personal data.
Consequently, we endeavour to protect your personal information and respect your privacy in accordance with best business practices and applicable regulations. Being committed to providing secure services to players, and we will take all reasonable precautions to ensure that all the data that you have submitted via the Website remains safe.
Player Accounts can only be accessed with the player’s unique ID and password. You may also set up two-factor authentication (2FA) as additional protection from unauthorised use of your account. You are responsible for keeping your login information confidential and making sure it cannot be accessed by another person.
10. YOUR RIGHTS
Data protection law gives you, as a data subject, certain rights in certain circumstances. In accordance with law, you have a right to:
- Request access to your personal data - This means that you have a right to request, free of charge, a copy of the personal data we hold about you;
- Request the correction of your personal data – This means that if any personal data we hold about you is incomplete or incorrect, you have a right to have this corrected. Keep in mind, however, that we may need you to provide evidence and documentation (such as your ID documentation or proof of address) to support your request. It can be declined due to our legal obligations
- Request the erasure of your personal data - This means that you may request the erasure of your personal data where we no longer have a legal basis to continue processing it or retaining it. Please be aware that this right is not absolute – meaning that we are not able to satisfy your request where we are obliged under a legal obligation to retain the data, or where we have reason that the retention of data is necessary for us to defend ourselves in a legal dispute;
- Object to the processing of your personal data where we rely on our legitimate interests (or those of a third party) to process your data and you feel that our processing of your data in such a manner impacts your fundamental rights and freedoms. However, in some cases, we may be able to demonstrate that we have a compelling legitimate ground to process your data which may override your rights and freedoms. You may submit your objections to processing of your personal data on the grounds of the above-mentioned legitimate company interests by contacting our DPO;
- Request the restriction of the processing of your personal data – You may ask us to temporarily suspend the processing of your personal data in one of the following scenarios: (a) where you want us to establish the accuracy of the data, (b) where our use of the data is unlawful but you do not wish for us to delete it, (c) where you need us to retain your data even when we no longer need it in order for you to establish, exercise, or defend legal claims, or (d) where you have objected the use of your data but we need to verify whether we have overriding legitimate grounds to use it;
- Request the transfer of your personal data (i.e. data portability) – This means you may request us to provide you with certain data we process about you so you may transfer it to another controller. This right only applies to data acquired through automated means which you initially provided consent for us to use, or where we used the data to perform our obligations under a contract with you;
- Withdraw your consent at any time where we rely on your consent to process the data - ‘Opting out’ or withdrawing your consent will not affect the lawfulness of the processing carried out by us up until the time you withdraw your consent. Withdrawing your consent means that, going forward, you no longer wish for us to process your data in such a manner. This means that you may no longer consent for us to provide you with certain services (such as marketing. You may withdraw your consent at any time through the account profile settings on the website;
- Lodge a complaint with a supervisory authority; In order to exercise your rights as explained above, we may need to request specific information about you to help us verify your identity. This is a security measure to ensure that we are certain that the person to whom we disclose your personal data is really you.
We will do our utmost to respond to all legitimate requests within a one-month timeframe from the submission of a request. If your request is particularly complex, or if you have made multiple requests in a certain time period, it may take us a little longer. In such a case, we will notify you of this extension.
11. CONTACTING US
You may always contact us in regards to this Policy should you wish to:
- Confirm the accuracy of the 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;
- 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.
- Right to withdraw consent. In cases where we rely on your consent for the processing of personal data, you have a right to withdraw your consent at any time.
In addition, as per Article 77 of the GDPR, you have a right to lodge a complaint related to your data processing to a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of an alleged infringement.
When you visit the Website, our system automatically collects information about your visit, such as your browser, IP address, and the referring website. This collection may be done in conjunction with our platform providers and partners. We may receive from them general demographic or usage data of our Website visitors. We do not use automatically collected information to identify you personally without receiving additional consent.
Required cookies: enable the navigation and basic functionality of the websites, e.g., access to member areas of the Website.
Functional cookies: allow us to analyse your website usage and your selections on the website (e.g. your session key, language, or region), so we can save these settings and offer you a more personalised experience.
Advertising cookies: allow us to gauge how effective our content marketing is. These cookies are provided by our partners to track website visits and new player registrations from advertising. We do not share your personal information (such as name or email) to affiliated partners except for site visit data collected directly by such Advertising Cookies. However your site visit data may be linked with other personal information collected through other sources by the providers. The latter external data processing is governed by the privacy notices and policies of these third-party providers.
In addition to the above, we use a number of third party service providers who also set cookies on this Website, in order to deliver the services that they are providing to us. Such services include, but are not limited to, helping us to improve your experience by tracking your activity on the Website, measuring the effectiveness of the Website and the effectiveness of our marketing campaigns. Most online browsers automatically accept cookies. If you prefer, it is possible to block some or all cookies, or to delete cookies that have already been set by modifying your browser settings. However, we recommend that you do not block or delete your cookies as this may restrict your use of our Website.
13. NETENT GAMES