Data Protection and Cookie Policy

The management of SpinBet Partners and its employees take the security and privacy of your personal data very seriously.

We are committed to making our privacy policy more transparent and understandable to you regarding the use and protection of your data. We have modified this Privacy Policy to comply with the standards of the EU General Data Protection Regulation (GDPR).

This Privacy Policy sets out our data practices and your ways of protecting personal data.

The Company bears responsibility for providing our customers with accurate information on how we use cookies and how we enable people on our website to properly set cookies.

If you have any requests, questions or suggestions regarding the Privacy Policy and the use of the services provided to you, please contact us at support@spinbet.partners.

Please also provide us with detailed information at support@spinbet.partners about the pages of our web resource on which the cookie settings are of concern to you.

SpinBet Partners is obliged to protect your personal data.

This Policy explains to you what kind of information we collect while providing our services, why we collect this information and how we use it.

Please pay your attention to the fact that this confidentiality policy will be agreed between you and SpinBet Partners (hereinafter referred to as “We”, “Us” or “Our”, if necessary).

We may make amendments to this Privacy Policy from time to time and will notify you of these changes by posting them on our resources.

We encourage you to review this Privacy Policy regularly.

RIGHTS OF PERSONAL DATA SUBJECT

The processing of your personal data in SpinBet Partners takes place only after you express an act of approval, establishing and confirming a freely given, specific, informed and unambiguous expression of consent to the processing of your personal data (hereinafter referred to as "Consent").

This consent you give us freely, voluntarily and in your best interest, specific, informed and conscious.

Your consent to the processing of personal data may be provided by you or your representative in any form that allows you to confirm the fact of its receipt, namely:

WRITTEN FORM

In such a case, the Consent must include the following information:

• last name, first name, patronymic (if any), address of the subject of personal data, number of the main identity document, information about the issue date and the issuing authority of the mentioned document; or last name, first name, patronymic (if any), address of the representative of the subject of personal data, number of the main document proving their identity, information about the issue date and the issuing authority of the mentioned document, details of a notarized power of attorney or other document confirming the authority of this representative (upon receipt of consent from the representative of the subject of personal data);
• a postal address of SpinBet Partners receiving the consent of the subject of personal data; purposes of personal data processing;
• a list of personal data, the processing of which the subject of personal data gives their consent to;
• a name and an address of a person carrying out the processing of personal data on behalf of SpinBet Partners, if the processing is entrusted to such a person;
• a list of actions with personal data for which the consent is given, a general description of personal data processing methods;
• a period during which the consent of the personal data subject is valid, as well as the method of its withdrawal;
• a signature of the personal data subject.

IN THE FORM OF IMPLICATIVE ACTIONS of the personal data subject, expressing their intention to establish legal relations with SpinBet Partners, but not in the form of an oral or written declaration of will, but by behavior that can be used to draw a conclusion about such intention (for example, registration on the SpinBet Partners website, registration on the services of SpinBet Partners, making money transactions that serve as a condition for participation in gambling in accordance with the rules of SpinBet Partners, on your individual account received during registration on the SpinBet Partners website, registering bets through your personal account and receiving winnings through your personal account, compliance with the rules established by the organizer of gambling, etc.).

The processing of your personal data at SpinBet Partners does not require your Consent in the following cases:

• personal data processing is necessary to achieve the goals provided for by international treaties or the laws of local jurisdictions, to exercise and fulfill the functions, powers and duties assigned by law;
• personal data processing is necessary for administration of justice, execution of a judicial act, any act of another body or official, subject to execution in accordance with local laws;
• personal data processing is necessary to protect your life, health or other vital interests;
• personal data processing is necessary to exercise the rights and legitimate interests of SpinBet Partners or third parties, or to achieve socially significant goals, provided that the rights and freedoms of your personal data are not violated;
• personal data processing is carried out for statistical or other research purposes, subject to the mandatory depersonalization of your personal data, except for the processing of personal data for marketing purposes;
• personal data processing, access to which is provided by you to an unlimited number of persons;
• personal data processing subject to publication or mandatory disclosure in accordance with the laws of local jurisdictions.

Procedure for withdrawing consent to personal data processing, procedure for obtaining information about the availability of your personal data at SpinBet Partners, procedure for clarifying, blocking and destroying your personal data at SpinBet Partners upon request are regulated by the General Data Protection Regulation (GDPR), which is fully implemented by us.

We collect and process data, that can be used for personality identification purposes, including, but not limited to, first and last name, date of birth, credit card information, home or other physical address, email address, telephone number or other relevant Personal data (hereinafter referred to as "data").

You may be asked to provide personal data when using our website or services and registering an account.

The personal data we collect may include:

• contact details (including phone number, email address),
• location information (postal address),
• data on payments,
• transaction history,
• website use preferences,
• feedback on Services.

Such data is collected, processed and stored by us on servers in accordance with the requirements of the legislation of your state.

When you use our services, our servers store your unique activity log, which collects certain administrative and traffic data, including:

• initial IP-address,
• access time,
• access date,
• web-pages visited,
• language used,
• software crash reports,
• type of browser used.

This data is necessary for providing high-quality services. We never collect personal data about you without your knowledge.

We may automatically collect certain data, as mentioned above, and receive from you the Personal data that you voluntarily provide to us, through services, messages and interactions on the SpinBet Partners website.

We may receive personal data from online merchants, service providers as well as from legally acquired from third party vendors customer lists.

In addition, we may use third party vendors to provide technical support for online transactions and account maintenance.

We will have access to any data you provide to such vendors and third party e-commerce services and will use personal data in accordance with the provisions of this Privacy Policy.

This data will be disclosed to third parties outside the company only in accordance with this Privacy Policy and the laws of your state.

We use the personal data given to us to provide services, to support you as a customer, for security purposes, for identification and verification purposes, to process any online transactions, to help you participate in third-party promotions that meet certain business needs. requirements, and for any other purposes related to the operation of our gambling Services.

Therefore, in the course of providing services we may share your personal data with our partners, carefully selected by us (including any other parties that have agreements with you to share your data).

Your personal data may also be used by us to provide you with:

• advertising offers and information on our products and services;
• advertising offers and information on our partners’ products and services for broadening the range of Services provided to you and improving the quality of services we provide to our customers.

From time to time, we may ask you for information through surveys or contests. Participation in these surveys or contests is absolutely voluntary and you always have the choice of whether or not to disclose your personal data.

Information requested may include contact details (such as name, mailing address, telephone number) and geographic information (such as postal code or postal address), age.

By entering any contest or receiving winnings from us, you agree that we will use your name for promotional purposes without further compensation, except where prohibited by law.

Unless you have made a final decision whether or not to receive promotional information from us, we may use your personal data (including email address and telephone number) to provide you with information about our products, services and promotions, including gaming products and services (online-poker, casino, betting, backgammon, etc.) of third parties carefully selected by us.

We do not disclose your Personal data to companies, organizations or individuals not affiliated with SpinBet Partners.

We may provide information about you to companies, organizations or individuals not associated with SpinBet Partners in case you have provided us with your consent to these actions.

We may disclose your Personal data if required by the laws of your state, if you are found to have cheated or attempted to cheat us or any other user in any way (game manipulation, payment fraud, etc.) or if we believe that such actions are necessary for:

• compliance with any legal issue or process that affects us on any of our websites, or any of our services, or under circumstances where we become subject to legal obligations;
• protection of our property rights;
• protection of our users or the public.

If we have reason to suspect you of payment fraud, including the use of stolen credit cards or any other fraudulent activity, including payment cancellation or prohibited transactions such as money laundering, etc., we reserve the right to share this information, as well as your personal data, to other online gaming websites, banks, credit card companies, relevant regulatory agencies and law enforcement agencies.

In order to carry out government programs to prevent gambling addiction, your data may also be transferred to the relevant institutions.

You can "opt out" of receiving any promotional communications:

• by changing the settings in your account;
• by emailing us in response to a promotional message you have received from us;
• at any time by sending an email or writing to customer support;

in addition, you can contact us at any time, if you:

• want to know what personal data we collect, process and store, as well as from what sources we have received it;
• want to confirm the accuracy of your personal data that we have collected about you;
• would like to update your personal data;
• want to file a complaint regarding our use of your Personal data.

We may update any information provided to us if you prove the need for such changes and pass identification.

For the avoidance of doubt, we further inform you that nothing in this Privacy Policy will allow us to refuse to provide your Personal data if we are required to provide it by the law of your state.

INFORMATION STORED ON YOUR DEVICE

When you use our services, we may, with your permission, store certain information on your device. This information is called COOKIES. These are small text files containing letters and numbers that are stored on your device and remember your preferences when you use our services, visit our websites and online pages.

We also use local shared objects or "flash cookies". "Flash cookies" are similar to browser cookies. They help us remember your preferences when you visit our websites and save the data needed to play video or audio content.

Neither cookies nor "flash cookies" can be used to access your device or use information on your computer.

Cookies and "flash cookies" are used by us solely for control purposes.

We use these controls only to track your use of our services by remembering your preferences.

Cookies help us track your traffic on our website, improve services and services for you, as well as simplify access to the website and increase interest in our services and services.

We use flash cookies and other cookies to show you advertisements that are more relevant and preferable to you.

IMPORTANT AND NECESSARY COOKIES

Important and necessary cookies are used to enable any user on our information or gaming resource to move around the website and use its features, such as accessing secure areas of the website or making financial transactions. Without these cookies, you will not be able to use our websites effectively.

REGISTRATION PROCESS

These cookies contain information collected during your registration; they will allow us to learn more about you as a customer and help us provide the right service. We may also use this data to understand your online interests and preferences, making your visits to our platforms and services more enjoyable and convenient.

OUR WEBSITE

For visitors to our website, we use cookies to collect information.

Our servers use three different types of cookies:

• "Temporary" cookies – this type of cookie is stored on your computer for the duration of your visit to the website. Session-based cookies help you navigate our website faster and, if you are a registered customer, this allows us to provide you with relevant information. These cookies are automatically deleted when you close your browser.
• "Persistent" cookies - this type of cookie will remain on your computer for a certain amount of time, set for each cookie separately. Flash cookies are also stored.
• "Analytical" cookies - this type of cookie allows us to recognize and count the number of visitors to our website and see how visitors use our services and facilities. This helps us improve how our websites work, for example by making it easier for you to log in and find what you are looking for.

It is up to you to decide and you always have the choice of agreeing and accepting or disagreeing and rejecting the receipt of cookies.

Most web browsers automatically accept cookies, but if you wish, you can change your browser settings to control your cookies.

You can use your web browser to:

• delete all cookies;
• block all cookies;
• allow all cookies;
• block third party cookies;
• clear all cookies when the browser is closed;
• open a "private browsing"/"incognito" session, that allows you to browse the Internet without saving local data;
• install add-ons and plugins to enhance browser functions.

Где найти информацию об управлении файлами cookie?

• Information on cookies for Internet Explorer
• Information on cookies for Chrome
• Information on cookies for Firefox
• Information on cookies for Safari
• Information on cookies for Opera

FLASH COOKIES

You can change the Flash Player settings yourself to prevent the use of Flash files. Your Flash Player Settings Manager allows you to take options and customize your preferences.

If you decide to completely disable all cookies in your browser, then, unfortunately, you will not be able to use certain resources and services on our websites, and some services will not work correctly, for example, in this case, we will not be able to save the interface language you have chosen.

In order to play on our services, you will need to send and receive money from us. To ensure the normal operation of such services, we may use third-party electronic payment systems in order to process the necessary financial transactions.

By agreeing and accepting this Privacy Policy, you voluntarily and unequivocally consent to the transfer to third parties of your personal data necessary for processing and conducting monetary transactions, including agreeing to the transfer of your personal data outside your country (when necessary).

We take steps to ensure that your privacy is protected when working with third party payment processors.

We reserve the right to conduct security checks at any time to confirm the registration data you provide and to verify the correctness of the use of our services and financial transactions in order to prevent possible violations of our Terms of Service and applicable law.

By using our services you agree to our Terms and Conditions and authorize us to use and share your personal data with third parties for the purpose of verifying the information you provide when registering and using our services, including, if necessary, sending the information outside your country.

Security checks may include, but are not limited to, financial reporting and other verification of your personal data that you provide to any third party databases other than ours.

We understand the importance of maintaining the security and practices necessary to maintain the confidentiality, integrity, and availability of information. We store all personal data that we collect directly from you in an encrypted and password-protected database located on our secure network behind active state-of-the-art firewall software.

Our services support SSL version 3 with 128-bit encryption.

We also ensure that our subsidiaries, agents, partners, affiliates and suppliers apply the same adequate security measures.

However, sending information over the Internet is generally not completely secure, and we cannot guarantee you the security of your data while it is in transit.

ANY DATA YOU SEND, YOU SEND AT YOUR OWN RISK.

SpinBet Partners has all security procedures in place to protect your data once received.

Our services are not intended for persons under the age of 18 or other legal age in your country.

Any person providing information to us through our services certifies that they are at least eighteen (18) years of age (or other legal age in your country).

It is our company policy to detect attempts by minors to gain access to our services, which may require additional security analysis.

If we become aware that a minor has attempted to provide or has provided us with their personal data through our services, we will not accept and delete such data from our databases.

Personal data collected by us may be stored and processed in any country in which we or our affiliates, suppliers, partners or agents provide gaming services and our gaming platform services.

By using our services and services, you expressly consent to the transfer of your data outside of your country (including to countries that cannot be assessed as having adequate privacy and personal data protection laws).

However, we take all reasonable steps to ensure that our agents, partners, affiliates and suppliers, wherever located, comply with our privacy standards in general and this Privacy Policy in particular.

We cannot protect the data you provide to a third party online website that links to our services, services or any other information collected by any third party that is a member of our affiliate program (if applicable) or in any other way, as these third party online services and websites are not owned by us and are operated independently of us.

Be careful.

Any information collected by third parties is subject to the privacy policy of those third parties, if any.

We are not responsible for events beyond our direct control.

Due to the complex and ever-changing nature of our technology and business practices, we provide, but do not guarantee, an error-free experience relating to the privacy of your personal data when you visit other websites that you have accessed through links located on our website. Websites that are outside of our control, much less covered by this Privacy Policy, should provide you with the opportunity to review their privacy policy. If you visit other websites, you should be aware that the operators of those websites may collect your personal data, which will be used by them in accordance with their privacy policies, which will differ from ours.

Be careful.

We do not guarantee the security of your data while it is in transit while being transmitted over communication channels.

ANY DATA YOU SEND, YOU SEND AT YOUR OWN RISK.

We are also not responsible for any direct or indirect damages arising from the misuse or theft of your Personal data.

Your use of our services constitutes your voluntary consent to this Privacy Policy and grants us the rights to collect, process and store your personal data.

This Privacy Policy should be read in conjunction with the terms of use of the electronic service providers and any additional applicable terms and conditions posted on our platforms and websites.

We will amend this Privacy Policy from time to time and will notify you of such changes by posting the amended terms on our platforms and websites.

Your continued use of our services following any changes to this Privacy Policy means that you unconditionally accept those changes.

This is our complete and exclusive privacy policy as of May 16, 2018 and supersedes any earlier version and only applies to https://spinbet.partners/.

We recommend that you review this Privacy Policy regularly so that you do not miss important changes to it.

SpinBet Partners takes all appropriate measures to combat money laundering and combat international terrorism (AML Policy). At the same time, the Company maintains a strong and principled position to prevent any kind of illegal activity, as well as all related regulatory legal acts. In order to fulfill these obligations, the Company has the right to report to the appropriate official authorities about suspicions regarding funds deposited by the user into the account and related to the financing of terrorism or money laundering activities that were obtained illegally. The Company is also obliged to block such funds and take other measures provided for by the rules of the AML policy.

Money laundering means:

• concealment or confidentiality of information about the true origin, source, location, means of disposal, movements, ownership or other rights to property obtained as a result of illegal activity (or property obtained in exchange for such property);
• converting, moving, receiving, possessing or using property obtained as a result of criminal activity (or property obtained in exchange for such property) in order to conceal the illegal origin of such property or to assist persons involved in criminal activity in order to avoid legal consequences of their actions;
• a situation in which property was obtained as a result of criminal activity committed in the territory of another state.

In order to counteract the penetration of criminal capital into the economy of the state and the spread of crime, many countries are constantly fighting money laundering and terrorist financing.

The company applies internal regulations and special programs of measures to help government and international organizations in the fight against money laundering and terrorist financing around the world.

By registering an account with the Company, you assume the following obligations:

• you warrant that you will comply with all anti-money laundering and counter-terrorist financing laws and regulations, including but not limited to the AML Policy;
• you confirm that you have no knowledge or suspicion that the funds used to replenish the account in the past, present or future are obtained from an illegal source or are in any way related to money laundering or other illegal activities prohibited by the current legislation or instructions of any international organizations;
• you agree to immediately provide us with any information we request in order to comply with applicable laws and anti-money laundering requirements.

The Company collects and stores documents proving the identity of the User, as well as reports on all transactions made on the account.

The Company monitors suspicious transactions on the User's account, as well as transactions carried out under special conditions.

The Company reserves the right at any time and at any stage to refuse the user to carry out the operation, if the Company has reason to believe that this operation has anything to do with money laundering and criminal activity. In accordance with international law, the Company is not obliged to notify the user that their activity is suspicious and information about it has been transferred to the relevant government authorities.

According to the internal AML Policy, the Company conducts initial and ongoing verification of the identity of players in accordance with the level of potential risk that the user represents. As part of these inspections, the Company has the right to carry out the following actions:

• require the provision of minimum data to verify the identity of the player;
• record and store data and documents proving the identity of the user, as well as information about which methods were used to verify the identity, and the results of checks;
• check the personal data of clients for matches with the list of persons suspected of terrorism, formed by authorized state and independent bodies. The minimum set of user identification data includes: full name, date of birth, address of residence or registration;
• request the source of origin of funds that the user plans to deposit into the account.

To verify and confirm the authenticity of the data mentioned above, the Company may require the User to provide the following documents:

• passport, or identification card, or any other document replacing them that meets the following requirements: contains the name, date of birth and photograph of the owner of the document; has been issued by national government authorities;
• a recently received utility bill (not older than 3 months) or other document confirming the address of residence of the User.

The Company may also request any other additional information, which will need to be confirmed by relevant documents. In certain cases, the Company may require notarized copies of documents.