spin88 Privacy Policy

This Privacy Policy ("Policy") is issued by spin88 ("spin88", "we", "us", or "our") and applies to all personal data collected through the spin88 website at spin88.bid, its mobile applications, and any related services, features, or content offered by spin88 (collectively, the "Platform").

spin88 is committed to protecting the privacy and personal data of all users ("you" or "your") in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC").

By accessing or using the spin88 Platform, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must discontinue use of the Platform immediately.

This Policy should be read together with spin88's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated herein by reference.

spin88 collects the following categories of personal data from users of the Platform:

Category	Examples	Required?
Identity Data	Full legal name, date of birth, nationality, government-issued ID number	Yes — KYC
Contact Data	Email address, Philippine mobile number, residential address	Yes — Registration
Financial Data	GCash number, PayMaya account, BPI/BDO/Metrobank account details, transaction history	Yes — Payments
Gaming Data	Game history, bet amounts, win/loss records, session duration, bonus usage	Yes — Operations
Technical Data	IP address, device type, browser type, operating system, login timestamps	Yes — Security
Usage Data	Pages visited, features used, click patterns, referral source	Optional — Analytics
Communications Data	Support chat transcripts, email correspondence, feedback submissions	When applicable

spin88 does not collect sensitive personal information as defined under the DPA (such as health data, political affiliations, or religious beliefs) unless specifically required by law or regulatory obligation.

spin88 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated technologies: Data collected automatically when you access the Platform, including cookies, web beacons, server logs, and similar tracking technologies as described in Section 8;
• Third-party sources: Data received from identity verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), fraud prevention services, and analytics partners, where permitted by applicable law;
• Publicly available sources: Data from public records or databases where relevant to verifying your identity or complying with anti-money laundering obligations.

spin88 will always inform you at the point of collection what data is being collected and for what purpose. You will not be required to provide personal data beyond what is necessary for the specific service or feature you are accessing.

spin88 processes your personal data only for specific, legitimate purposes. The primary purposes for which we process your data, and the legal basis for each, are as follows:

• Account creation and management — necessary for the performance of our contract with you as a registered spin88 player;
• Identity verification (KYC) — required by applicable anti-money laundering regulations and our legal obligations under Philippine law;
• Processing deposits and withdrawals — necessary for the performance of our contract and to facilitate payment services via GCash, PayMaya, BPI, BDO, and Metrobank;
• Providing gaming services — necessary for the performance of our contract, including delivering game results, calculating winnings, and managing your account balance;
• Fraud prevention and security — legitimate interest in protecting the Platform and its users from fraudulent activity, unauthorized access, and abuse;
• Responsible gaming compliance — legal obligation to monitor gaming behavior and enforce self-exclusion and deposit limit requests;
• Customer support — legitimate interest in resolving your queries and improving service quality;
• Marketing communications — based on your consent, where you have opted in to receive promotional materials from spin88;
• Legal and regulatory compliance — compliance with applicable Philippine laws, court orders, and regulatory requirements.

spin88 will not process your personal data for any purpose incompatible with those listed above without first obtaining your explicit consent or establishing a separate lawful basis under the DPA.

spin88 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers necessary to process your transactions;
• KYC and identity verification providers: Third-party services engaged to verify your identity and age in compliance with regulatory requirements;
• Fraud prevention and security services: Providers that help spin88 detect and prevent fraudulent activity, money laundering, and unauthorized access;
• IT and platform infrastructure providers: Cloud hosting, database management, and technical support providers who process data on our behalf under strict contractual obligations;
• Regulatory and law enforcement authorities: Government agencies, courts, or law enforcement bodies where disclosure is required by Philippine law or a valid legal order;
• Professional advisers: Lawyers, auditors, and consultants bound by professional confidentiality obligations, where necessary for spin88's legal or business operations.

Where spin88 engages third-party processors, we ensure that appropriate data processing agreements are in place that require those processors to handle your data in accordance with the DPA and this Policy. spin88 remains responsible for the processing of your personal data by its authorized processors.

spin88 does not transfer personal data outside the Philippines unless the receiving jurisdiction provides an adequate level of data protection or appropriate safeguards are in place as required by the NPC.

spin88 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements;
• Financial transaction data: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine financial regulations;
• Gaming history: Retained for a minimum of three (3) years from the date of each gaming session;
• Support communications: Retained for two (2) years from the date of the last interaction;
• Marketing consent records: Retained until you withdraw your consent or for three (3) years from the date of consent, whichever is earlier;
• Technical and usage data: Retained for up to twelve (12) months from collection, unless required for longer for security or fraud investigation purposes.

Upon expiry of the applicable retention period, spin88 will securely delete or anonymize your personal data in accordance with its data disposal procedures. Where data is anonymized, it may be retained indefinitely for statistical and analytical purposes without further notice to you.

spin88 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption : All data transmitted between your device and the spin88 Platform is encrypted using industry-standard SSL/TLS protocols;
• Encrypted data storage: Sensitive personal and financial data is encrypted at rest using AES-256 encryption;
• Access controls: Access to personal data is restricted to authorized spin88 personnel and processors on a strict need-to-know basis, enforced through role-based access controls;
• Multi-factor authentication: spin88 systems require multi-factor authentication for administrative access to data processing systems;
• Regular security audits: spin88 conducts periodic vulnerability assessments and penetration testing to identify and remediate security weaknesses;
• Incident response procedures: spin88 maintains documented procedures for detecting, reporting, and responding to personal data breaches in accordance with NPC notification requirements.

While spin88 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is entirely secure. You are responsible for maintaining the confidentiality of your spin88 account credentials and for notifying us immediately at [email protected] if you suspect any unauthorized access to your account.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, spin88 will notify the NPC and affected users in accordance with the timelines and procedures prescribed under the DPA and its Implementing Rules and Regulations.

spin88 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, and gather analytics data that helps us improve our services. A cookie is a small text file placed on your device when you visit the Platform.

spin88 uses the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled without affecting core Platform functionality;
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience;
• Analytics cookies: Used to collect aggregated, anonymized data about how users interact with the Platform, including pages visited, time spent, and navigation paths. This data helps spin88 improve the Platform's design and content;
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic on the Platform.

spin88 does not use third-party advertising or behavioral tracking cookies. You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may impair your ability to use certain features of the Platform, including the spin88 Login function.

By continuing to use the spin88 Platform after being presented with our cookie notice, you consent to the use of cookies as described in this Section.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by spin88:

• Right to be informed: You have the right to be informed of how your personal data is being collected, processed, and used by spin88, as set out in this Policy;
• Right of access: You have the right to request a copy of the personal data spin88 holds about you, along with information about how it is being processed;
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data spin88 holds about you;
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to spin88's legal retention obligations;
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on spin88's legitimate interests;
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission if you believe spin88 has processed your personal data in violation of the DPA.

To exercise any of the above rights, please contact spin88's Data Protection Officer at [email protected] with the subject line "Data Privacy Request." spin88 will respond to all verified requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. spin88 may request proof of identity before processing any data rights request.

The spin88 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. spin88 does not knowingly collect personal data from individuals under the age of 21.

As part of the KYC verification process, spin88 requires all registering users to submit valid government-issued identification confirming their date of birth. Any account found to belong to a person under 21 years of age will be immediately suspended, all associated personal data will be deleted in accordance with this Policy, and any funds held in the account will be handled in accordance with applicable regulatory requirements.

If you believe that spin88 has inadvertently collected personal data from a minor, please contact us immediately at [email protected] so that we may take prompt corrective action.

spin88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will notify you by posting a prominent notice on the Platform and, where required by law, by sending a direct notification to your registered email address or Philippine mobile number.

The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision. Your continued use of the spin88 Platform following the posting of any amendment constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically to stay informed about how spin88 protects your personal data.

If any amendment materially reduces your rights or increases spin88's ability to use your personal data in ways not previously disclosed, spin88 will seek your renewed consent where required by the DPA before applying such changes to your existing data.

spin88 has designated a Data Protection Officer ("DPO") responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Policy, you may contact the spin88 DPO through the following channel:

• Email: [email protected] (subject line: "Data Privacy Request")
• Response time: Within fifteen (15) business days of receipt of a verified request
• Operating hours: 24/7 support availability for urgent data security concerns

If you are not satisfied with spin88's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012. Information on how to file a complaint with the NPC is available through official Philippine government channels.

spin88 is committed to resolving all data privacy concerns promptly, fairly, and in full compliance with applicable Philippine law. We value the trust you place in us when you share your personal data, and we take that responsibility seriously.