Spinarahub Privacy Policy

VERSION: 4.0

PUBLISHED: 12.11.2025

At Spinarahub, we are committed to protecting your privacy and maintaining your trust. This Privacy Policy explains what personal data we collect, how and why we use it, and the measures we take to keep it secure.

This Privacy Policy (“Privacy Policy”) describes how Spinarahub collects, uses, stores, and discloses information about users (“Users”) when they interact with **www.spinarahub.com**, including any subdomains, subpages, successor sites, or applications that access or integrate with the website (the “Website”). It applies to the Website and to all products and services made available through it.

This Privacy Policy applies to information we collect:

Through the Website;
Via email, text, live chat, or other electronic messages between you and the Website;
Through mobile and desktop applications you download from this Website or otherwise, which provide dedicated non-browser-based interaction between you and the Website; and
When you interact with our advertising and applications on third-party websites and services, where those applications or advertising include a link to this Privacy Policy.

This Privacy Policy does not apply to information:

Collected offline or through other channels; or
Collected by any third party, including via any application or content (including advertising) that may link to or be accessible from the Website.

Please read this Privacy Policy carefully to understand how we handle your personal information. If you do not agree with our practices, you should not use the Website. By accessing or using the Website, you acknowledge and agree to this Privacy Policy.

We may update this Privacy Policy from time to time (see “11. Changes to This Privacy Policy”). Your continued use of the Website after any updates are posted will be deemed acceptance of those changes, so we encourage you to review this Policy regularly.

1. Data Controller

This Privacy Policy is issued on behalf of Spinarahub. When we refer to “Spinarahub”, “we”, “us” or “our” in this Privacy Policy, we are referring to the entity within the Spinarahub group acting as the data controller and responsible for processing your personal information.

2. Type of Information We Collect and How Long We Keep It

We collect both personal information and anonymous information, and we may also create aggregate information based on these categories (see “12. Definitions”).

Examples of the information we may collect include:

Contact details – such as first and last name, email address, residential address, and mobile or landline numbers.
Personal information – such as gender, age or age range, and your image where provided.
Account information – including username, password, profile images, and other account-related details.
Transaction information – details you provide when making a purchase or using the Website or customer support, such as postal address, phone number, and payment information (including banking and card details, and where applicable, supporting financial documentation).
Communications – information exchanged between you and us via text message, live chat, posts, or similar communication tools.
Third-party data – information we obtain from platforms or partners (such as social networks, including Facebook) about your interaction with our services, where permitted.
Location data – such as approximate or precise location derived from your device or IP address, where lawful.
Activity, technical and device information – including pages viewed, time spent on the Website, frequency of use, how you discovered our Website, preferences, interaction with content, device type, hardware model, operating system, browser type, unique identifiers, and IP address.
Government-issued identification – such as a Social Security Number or other ID where required for legal, tax, “know your customer” (KYC), anti-fraud, or anti-money laundering purposes.

How Long We Retain Data

We retain your personal information only for as long as necessary to fulfil the purposes set out in this Privacy Policy, unless a longer period is required or permitted by law. For UK residents, the following table summarises the categories of personal information collected in the last 12 months and our intended retention period:

A. Identifiers

Examples: Name, alias, postal address, email address, phone number, account name, IP address, government-issued identifiers

Collected: YES

Retention: 3 years – for account management, legal obligations, and operational purposes

B. Personal and financial information

Examples: Bank account details, card information, employment history, certain financial/insurance data, health or medical information where applicable

Collected: YES

Retention: 3 years – for contractual, audit, and legal compliance purposes

C. Special category data

Examples: Racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic/biometric data, health data, sexual orientation, sex/gender

Collected: YES (only where lawful and strictly necessary)

Retention: 3 years – processed only with a valid legal basis (e.g. explicit consent, legal obligation, or legitimate interest)

D. Commercial information

Examples: Records of products or services purchased, considered or used; browsing and consumption preferences

Collected: YES

Retention: 3 years – for marketing analysis, customer relationship management, and service improvement

E. Biometric or genetic information

Examples: Fingerprints, facial templates, iris scans, DNA data

Collected: NO

F. Online activity and interaction

Examples: Website browsing history, search records, interactions with adverts, in-app usage

Collected: YES

Retention: 3 years – to improve services, security, and Website experience

G. Location data

Examples: GPS or device location

Collected: YES

Retention: 3 years – to provide location-based services and improve platform features

H. Sensory data

Examples: Audio, video, thermal or similar sensory data

Collected: NO

I. Employment/professional data

Examples: Job history, performance reviews, qualifications

Collected: NO

J. Educational data

Examples: Student records, grades, transcripts

Collected: NO

K. Inferences / profiles

Examples: Preferences, characteristics, trends, behaviour patterns

Collected: NO (or only in limited form, and solely to improve or personalise services)

Retention: 3 years – where generated, used only for service enhancement and personalisation, subject to applicable law

3. How We Collect Your Information / Sources of Information

We collect information in a variety of ways, including when you:

Visit or browse Spinarahub.com;
Register for an account;
Make a purchase or conduct transactions on the Website;
Respond to surveys or promotions;
Complete forms; or
Use features, services, or tools we offer on the Website.

We also collect information when you contact us by:

Telephone or video call;
Email or live chat;
Postal mail;
Text message; or
Social media.

Telephone or video calls between Users and Spinarahub representatives may be recorded for training, quality control, and compliance purposes. By continuing a call, you consent to that recording.

We also collect data about your use of our services using technologies that may be active when you visit our Website or use our applications via third-party sites or platforms (whether or not you are logged in). These include cookies, flash cookies, pixels, tags and application programming interfaces (“APIs”). See “5. Personal Data Collected via Technology” for more information.

Analytics tools are used to help us understand how you interact with the Website and our applications or services on third-party platforms.

We may also rely on trusted external sources to validate or update information you have provided (for example, to confirm postal address, identity documents, or name spelling).

4. How We Use Collected Information

The Data Controller is responsible for processing your data for the purposes described in this Privacy Policy. Other members of the Spinarahub group may access your information as data processors on our behalf, where necessary.

Broadly, we use your information to:

Operate the Website and deliver our products and services;
Facilitate and manage transactions;
Respond to your queries and support requests; and
Comply with legal, regulatory, and anti-fraud obligations.

Subject to applicable laws and any choices available to you, Spinarahub may use your information for the following specific purposes:

To provide and manage the services you request

Including processing your registration, maintaining your account, and carrying out checks to prevent fraud, misuse, or unauthorised activity.

To improve customer service and our services

Information you share helps us respond more efficiently to your requests and improve our products, features, and support processes.

To process payments and other transactions

We use transaction and financial information to complete purchases, verify payment details, meet customer due diligence requirements, and where necessary, confirm the lawful source of funds. We share such data only to the extent needed to provide the service or comply with legal obligations.

To personalise your experience

Aggregated and anonymised data may be used to understand how Users as a group use the Website and to tailor content, layout, or recommendations.

To contact you about our services

Including by email, live chat, mail, text message, or social media, for example to inform you about features, account-related matters, promotions you choose to join, surveys, and other service updates. Provision of a telephone number can be treated as consent to receive certain automated text messages, where allowed by law (see “13. Contacting You via Email or Text”).

To send important notices

For example, confirming transactions, informing you about changes to our terms, policies, or technical updates. These service-related notices are important to your use of the platform and are generally not subject to opt-out.

To comply with legal and regulatory obligations

We may use your information to monitor activity for responsible social gaming purposes, fulfil tax obligations, perform anti-fraud and anti-money laundering checks (including source of funds verification), and comply with other applicable laws or regulatory requirements.

To support alternative dispute resolution

We may share relevant information with independent third-party dispute resolution providers where necessary to resolve complaints that cannot be settled through our internal processes.

We do not use automated decision-making in a way that falls within the strict meaning of European data protection laws, where such decisions have legal or similarly significant effects without appropriate human involvement.

5. Personal Data Collected via Technology

When you interact with our Website, we want your experience to be efficient and user-friendly. We and our partners use industry-standard technologies to achieve this, including:

Cookies – Small text files placed on your device to store preferences and settings. Most browsers allow you to block or delete cookies, but doing so may affect certain site functions. If your browser is set to accept cookies, our system will place them when you access the Website.

Pixel tags / web beacons – Small pieces of code on our Website or in our emails that help us understand whether pages have been visited, content has been viewed, or emails have been opened or forwarded.

Mobile device identifiers – Advertising identifiers associated with your device (e.g., Apple IDFA, Google Advertising ID) may be used to support interest-based advertising and measurement.

Event tagging – Tools (including Facebook App Events and similar tracking) record certain actions on the Website, such as app installs or purchase events, enabling analytics, ad performance measurement, and audience building.

Behavioural advertising – We may work with third-party partners to display advertising on our Website or on other sites and apps. These partners may use cookies and similar technologies to collect information about your browsing activity and interests, in order to provide more relevant advertising. We do not control these third parties’ tracking technologies, and you should review their own policies for details.

For more information about managing cookies and interest-based advertising, please refer to your browser settings and any additional opt-out links we may provide on the Website.

6. Your Rights Over Your Information

General Rights

Depending on where you live and subject to legal conditions, you may have rights in relation to the personal information we hold about you, such as:

The right to access your personal data;
The right to correct inaccurate or incomplete data;
The right to object to certain processing activities;
The right to obtain a copy of personal information in portable form;
The right to withdraw consent, where processing is based on consent; and
In some cases, the right to request deletion of your personal data.

These rights may not be absolute and can be limited by applicable law or regulatory requirements. We may also update or correct data ourselves where appropriate.

You also have the right to lodge a complaint with the relevant data protection supervisory authority if you are unhappy with how we process your personal information.

Rights in Direct Advertising

If we process your personal information for direct marketing, you can object at any time. This includes any profiling linked to direct advertising.

You may opt out of marketing communications by following the instructions in any such message or by contacting Customer Support. Once you object, we will stop using your personal information for direct marketing.

Data Deletion Requests

To protect your privacy, we require Users to verify their identity before we process a request to delete account data.

Verification may include confirmation via email, phone, or other secure methods. This helps us ensure the request is coming from the rightful account holder.

Opt-Out Preference Signals

Under UK GDPR, you may limit or prevent the collection of non-essential data via your device. You can:

Adjust browser/device settings to block cookies or other tracking technologies; and
Enable Global Privacy Control (GPC) or similar tools in your browser, where supported.

Blocking cookies or similar technologies may affect certain Website features.

If we provide an online opt-out tool for interest-based advertising, you can use it to limit such data use. Users in other jurisdictions (including the EU) should refer to applicable regional opt-out mechanisms. We will honour valid opt-out signals on a per-browser basis where required.

UK Data Subject Rights

Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, UK residents have additional rights, including:

Right of Access – To request confirmation that we process your data and to receive a copy along with information about how it is used.
Right to Rectification – To correct inaccurate or incomplete personal information.
Right to Erasure – To request deletion of your data, subject to legal or contractual obligations that may require us to retain it.
Right to Restriction – To request limited processing where, for example, you dispute accuracy or object to processing.
Right to Object – To object to processing based on legitimate interests or for direct marketing (including profiling).
Right to Data Portability – Where applicable, to receive your data in a structured, commonly used, machine-readable format and transmit it to another controller.

How to Submit a Request

To exercise these rights, you or an authorised representative must:

Provide sufficient information to verify your identity (e.g., full name, email address, and any other reasonably requested details).
Clearly describe the request (e.g., access, correction, deletion, restriction, objection, or portability).

We aim to respond within one month of receiving a valid request. If a request is complex or numerous, this period may be extended by up to two additional months, and we will inform you of the extension and reasons.

How to Exercise Your Rights

To exercise any of these rights, please email us at:

**[email protected]**

We may need to verify your identity and, where relevant, your place of residence before processing your request.

We will use information provided in connection with a data request solely to verify and fulfil that request. You do not need an account to submit a valid request.

Authorised Representatives

You may appoint an authorised representative to submit requests on your behalf. Written authorisation must confirm their authority to act for you. We may request a copy of this authorisation before processing the request.

We generally do not charge a fee for valid requests unless they are excessive, repetitive, or manifestly unfounded. If a fee is permitted by law and required, we will inform you before proceeding.

We will not treat you unfairly for exercising your rights. We will not deny services, charge different prices, or provide lower quality solely because you exercised a data right. However, where permitted by law, some service tiers may vary based on the amount and type of personal information provided.

In some jurisdictions, you also have the right to appeal our response. You can appeal by emailing:

**[email protected]**

We will respond to appeals within applicable legal timeframes and explain further steps if you remain dissatisfied.

7. How We Protect Your Information

We have physical, technical, and organisational safeguards in place to protect the information we collect. These measures are designed to protect against unauthorised access, use, alteration, disclosure, or destruction of your personal information, login credentials, transaction data, and other information stored on our systems. We review and update our security practices in line with technological developments.

Your security also depends on you. If you have a password for access to parts of the Website, you are responsible for keeping it confidential. Please do not share your password with anyone.

Unfortunately, transmission of information over the internet is not completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security during transmission. Any transmission is at your own risk. We are not responsible for circumvention of privacy settings or security features on the Website.

9. Sharing Your Information

We do not sell, trade, or rent Users’ personal identification information. However, we may share personal data in the following circumstances:

Within the Spinarahub Group

We may share information with other companies in the Spinarahub group for the purposes described in this Privacy Policy, including service provision, compliance, and internal administration. See “Transfers” below for more information.

With Third Parties

We share data with third parties only where necessary and lawful, including:

When you have allowed or requested us to share information;
To provide products and services or to inform you about important changes to functionality;
With service providers who support our operations (e.g., technology, hosting, data storage, payments processing, identity verification, or marketing services). These partners may access personal information only to perform services on our behalf and must not use it for other purposes, unless they act as independent data controllers under applicable law;
In response to lawful requests by public authorities, including to meet national security or law enforcement requirements or regulatory orders;
In connection with a merger, restructuring, sale, or transfer of Spinarahub assets;
Where we believe disclosure is necessary to protect the rights, property, or safety of Spinarahub, our Users, or others;
When financial institutions or regulators require information to satisfy legal obligations;
To enforce our Website terms and conditions, detect or prevent fraud or other illegal activities, and comply with applicable laws; and
To perform customer due diligence and identity verification.

We may ask you to provide your image to help verify your identity. For this, we may use facial recognition or similar technology supplied by trusted third parties (such as identity verification providers). These providers may process biometric data in line with their own privacy policies and share results with us. We retain such information only for as long as needed for the original purpose or up to three years from your last interaction with us, unless a longer period is required by law.

Categories of Information We May Share

In the last 12 months, we have disclosed certain personal information to third parties for legitimate business purposes, under UK GDPR and other data protection laws. We do not sell personal information.

A: Identifiers

Recipients: Merchants and payment partners involved in your purchases; third-party identity verification providers; game providers for eligibility checks

Purpose: Completing transactions, verifying identity, confirming eligibility

B: Contact and Account Information

Recipients: Merchants and payment partners; identity verification providers

Purpose: Facilitating transactions, account management, identity checks

C: Protected Characteristics (where required)

Recipients: Identity verification providers

Purpose: Verifying identity where legally required

D: Commercial Information

Recipients: Merchants or partners involved in your transactions

Purpose: Fulfilling purchases and providing related services

E–K

Biometric information, network activity, sensory data, employment, education, and inferences – only shared where specifically noted above and permitted by law; otherwise not routinely collected or disclosed.

Aggregated Information

We may share aggregated, non-identifiable statistics about Website usage with business partners, affiliates, or advertisers. This data does not identify individual Users.

Transfers

Spinarahub may operate in multiple jurisdictions. Your personal information may be transferred to, stored in, or processed in the UK, the European Economic Area (EEA), or other countries where we or our service providers maintain facilities.

Where required by law, we implement appropriate safeguards for international transfers, such as Standard Contractual Clauses or equivalent protections, to ensure your information receives an adequate level of protection.

10. Other Important Information

Children’s Privacy

The Website is not intended for individuals under 18 years of age. We do not knowingly collect personal information from anyone under 18. If you are under 18, do not use the Website or provide any information to us.

If we learn that we have collected personal data from a person under 18, we will delete that information. If you believe we might have information about a child under 18, please contact us at:

**[email protected]**

Do-Not-Track Signals

Some browsers send “Do-Not-Track” (DNT) signals. At present, there is no agreed industry standard on how websites should respond to these signals. Accordingly, our Website does not currently respond to DNT signals. If a standard is established, we will reassess our approach.

11. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our operations or legal obligations. Where required by law, we will notify you of material changes and obtain your consent.

Updates will be posted on the Website and become effective when published. We encourage you to review this page regularly to stay informed about how we protect and use your personal information.

12. Definitions

Personal information – Information that identifies, or can reasonably be used to identify, an individual (directly or indirectly). Examples include name, address, email address, and telephone number. When anonymous information is linked to personal information, it is treated as personal information.

Anonymous information – Information that does not identify, and cannot reasonably be used to identify, any individual.

Aggregate information – Information about groups or categories of Users that does not identify any individual and cannot reasonably be used to do so.

13. Contacting You via Email or Text

By providing contact details (including email address and mobile number), you confirm that:

The information is accurate; and
You are the owner or authorised user of the email address and/or phone number.

You agree that Spinarahub may contact you at these details, including via:

Pre-recorded voice messages;
Autodialled calls; and/or
Text messages,

in connection with:

This Privacy Policy and related terms;
Your account or transactions with Spinarahub; and
Promotional or service-related communications from Spinarahub, where permitted by law.

These communications may occur even if your number appears on a national or state “Do Not Call” list. Standard carrier charges may apply, and Spinarahub is not responsible for such charges.

You may adjust your communication preferences or opt out of certain types of messages where legally permitted, following the instructions in the message or by contacting us.

14. Contacting Us

If you have questions about this Privacy Policy, your personal information, or how we process it, you can contact our Data Protection Officer at:

Email: [email protected]

Please include your place of residence and a brief description of your question or request so we can assist you efficiently.