Spin Casino Privacy Policy

The Group

Several licensed firms sit beneath the Cityviews umbrella. One of them, Baytree Interactive Limited (company number 69691), has its registered seat in Guernsey — Ground Floor, Kingsway House, Havilland Street, St Peter Port — and trades under Kahnawake Gaming Commission licence 00892, granted on 16 February 2022. The other, Baytree (Alderney) Limited (company number 2012), is based in Alderney at La Corvee House, La Corvee, GY9 3TQ, holding Alderney Gambling Control Commission (AGCC) licence 155 C1 from 15 December 2020. Operation of the Services described here is shared between the two.

What Information Is Collected

What is gathered from users splits into two strands: information that identifies a person and information that does not.

The identifying (personal) information can cover:

• Card numbers, bank account data and other payment particulars.
• An official identity document plus proof of address, sought at the verification stage.
• Account-opening fields — a chosen username and password, first and last name, email, gender, birth date, postal address, country, ID number, telephone and occupation.
• Material received from outside providers, credit history and related financial data among it.
• The basic profile pulled from a social network where registration runs through one.
• Hardware and network markers such as a MAC address, IMEI, a device UDID, browser-fingerprint signals, IP address and geo-location readings.
• Logged emails, chat threads and call recordings, retained for support, staff training and security.
• Whatever a player volunteers in the course of reaching out to the brand.

The non-identifying strand consists of technical and aggregated signals picked up as people move around the Services — operating system, browser, screen resolution, language and keyboard choices, click paths, on-site actions, how long a visit lasts and the matching timestamps. Once any such signal is joined to identifying information, it is treated as personal information for the life of that link. The categories here run as follows:

• Usage analytics: log files, the pages opened, time on each, clicks and triggered alerts, all of it fuel for diagnostics and study.
• Play data: amounts deposited, stakes placed, bonuses, length of each session and top scores, some of which may appear on brand platforms.
• De-identified data: aggregated or anonymised records that can be drawn on or released without limit, advertising included.
• Environment details: browser and operating-system type, preferred language, sign-in times and the referring domain, used to tune the Services.
• Connection and device signals: read from installed software to guard against fraud, including whether a VPN or proxy sits on the link.

Minors

Eighteen is the minimum age for using the Services — or the local age of majority where that is higher — and no one under it should register or submit personal information. The information that arrives may be verified at the brand’s discretion, and any data shown to belong to an underage person is discarded. A parent or guardian who suspects that a child has sent something can write to the brand so that the matter is dealt with. Identity and age checks may recur at any time, and an account that cannot be linked to an adult may be paused for review.

How the Collected Information Is Used

The personal information on file supports a spread of activities, set out here:

• Opening, administering and refreshing player accounts.
• Running day-to-day operations such as bet settlement and payments.
• Confirming identity and granting entry to specific features.
• Guarding against fraud and unlawful conduct, and looking into breaches of the rules or the User Agreement.
• Meeting statutory and regulatory duties, customer due diligence (KYC), anti-money-laundering steps and lawful requests among them.
• Keeping play responsible and resolving disputes that arise from the Services.
• Sending news, updates and tailored offers, behavioural advertising included.
• Measuring usage through analytics, statistics and research to improve and individualise the Services.
• Running customer relations, help-desk support and fault resolution.
• Acting on requests that relate to user rights.
• Tailoring and building out the Services around player preferences.
• Delivering advertising and gauging how well campaigns perform.
• Authenticating logins and flagging unusual account behaviour.
• Carrying out internal record-keeping, audits and regulatory reporting.

Marketing

Promotional material about the Services and neighbouring products may be sent out by Spin Casino, or by the subcontractors it engages, drawing on a player’s name, postal and email addresses and phone number. The senders can be other Group companies, White Label Brands, or the partners and affiliates that the Group works with (the «Marketing Affiliates»), and the channel may be email, post, SMS or a phone call. Adjusting what arrives is done through Customer Services at any time. Should the Group’s software be downloaded, a notification component may be installed on your device to push word of new features, offers and promotions; switching it off means removing that component by hand. Declining further approaches is equally possible at any moment over Live Chat, though messages about the service itself keep coming even once the marketing email is switched off.

With Whom Information Is Shared

Selling or renting personal information never happens; it passes to others strictly where a stated purpose — data storage, payment handling and authentication, audits, fraud control, research and diagnostics, targeted promotion, or the safeguarding of legal rights and safety — makes it necessary. The parties that may receive it are:

•  Banks, payment processors and payment-service providers.
• Cloud-hosting firms, identity-verification and fraud-prevention specialists, marketing affiliates and other subcontractors.
• Fellow Group companies, affiliated businesses, and White Label Brands with their providers.
• Credit-reference agencies.
• Regulators, licensing authorities and government bodies.
• Police, banks or officials engaged in detecting or stopping fraud and unlawful acts.
• Firms that operate or promote In-House and White Label Brands.
• Event and tournament organisers, along with the hotels and airlines attached to such occasions.
• Auditors, contractors and advisers reviewing the Group’s processes.
• Prospective purchasers or investors, and the counterparties to any sale, merger or restructuring.

Transfer of Information

Operating worldwide means a player’s personal information may be routed to places outside New Zealand and the European Union, where statutory protection can be lighter than at home. Contractual safeguards — approved transfer clauses among them — or comparable measures are applied so the information stays protected in line with this notice. New Zealand players remain under the Privacy Act 2020 even after their data crosses a border, and any overseas handler is expected to match an equivalent standard, so that the same standard of protection applies regardless of where your data is processed. Anyone who senses a breach of privacy or misuse of the Services can raise it on Live Chat.

Tracking Technologies and Cookies

Cookies, web beacons, pixels, scripts, tags and kindred tools (the «Tracking Technologies») are set by Spin Casino and by authorised outside parties whenever the Services are visited or used. Working on their own, they record facts about the player and the device to ease movement around the site, raise performance and tailor the experience, and they also back statistics, analytics and interest-based content; a portion of the same data reaches third parties by these means. A cookie is simply a short text file stored on a device that holds on to settings and preferences and helps pages behave smoothly. Inspecting, deleting or blocking these files is something most browsers permit, yet switching them off can leave portions of the Services functioning poorly. Fuller information lives in the Cookie Policy. The Services do not react to automated browser signals such as Do Not Track, yet cookie choices can be managed within browser settings, and certain third-party advertising cookies can be turned off through the relevant industry opt-out tools.

Third-Party Services

From time to time, the Services display links to external sites, apps or services outside the Group. Coverage under this notice stops at those links, and responsibility for how such third parties treat privacy, or for their legal terms, does not rest with Spin Casino. Going through their policies and conditions first is the sensible course, and whatever risk attaches to those external destinations falls on the player.

Retention of Personal Information

Personal information linked to an account is kept while that account stays live. Holding it longer can be required by legal duties — gambling regulation, customer due diligence (KYC) and anti-money-laundering rules, among them, or justified by a legitimate interest such as fraud prevention and record keeping. When a player asks by email for personal information to be removed, Spin Casino puts reasonable effort into honouring the request.

User Rights

On its own initiative, the brand may put right, refresh or strike out information that is patchy or wrong. Subject to the limits the law imposes — gambling regulation and reporting duties under the Privacy Act 2020 included — a player is entitled, at any time, to request that Spin Casino:

• Hands over or deletes the personal information held.
• Fixes or brings that information up to date where it is mistaken.
• Reins in or stops any further use of it.
• Supplies it in a machine-readable format.

How Information Is Kept Secure

Keeping player information protected receives close attention. Barriers to physical and keeping player information protected receive close attention. Barriers of a physical and technical kind work to shut out unauthorised access, hold the data secure and see that it is used correctly, with the strength of each barrier matched to how sensitive the material is. The toolkit follows recognised practice:

• a hardened network layout fitted with firewalls and intrusion prevention;
• encryption in transit;
• authentication paired with access control;
• review through both internal and external audits.

Changes to This Privacy Notice

Revision of this Privacy Notice can occur whenever needed, which makes an occasional look at the page worthwhile. Anything significant is signalled through the Services or by email and takes hold seven days from that notice; smaller edits apply from the «Last Revised» stamp shown on the page, and continued use of the Services after that date constitutes your acceptance of the updated notice.

How to Make Contact and Supervisory Authority

Anything unclear about the Services, or about what is collected and the use it is put to, can be raised over the chat facility, where a reply is aimed for within a reasonable window. Data-protection complaints from New Zealand players may additionally go to the Office of the Privacy Commissioner, the country’s authority for the Privacy Act 2020. When the Group’s home regulator is the one in point, that is the Office of the Data Protection Authority (ODPA) in Guernsey, reachable via www.odpa.gg.