Privacy Policy
Last updated: December 2024
1. Introduction
Spinary ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website spinary.com.
Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site.
2. Data Controller
For the purposes of applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, the data controller is:
Spinary
Email: privacy@spinary.com
If you have any questions about this Privacy Policy or our data practices, please contact us using the details above.
3. Information We Collect
3.1 Information Collected Automatically
When you visit our website, we may automatically collect certain information about your device and usage, including:
- Browser type and version
- Operating system
- IP address (anonymised where possible)
- Pages visited and time spent on pages
- Referring website addresses
- Date and time of your visit
3.2 Cookies and Tracking Technologies
We use cookies and similar tracking technologies to track activity on our website and hold certain information. For detailed information about our use of cookies, please see our Cookie Policy.
4. Legal Basis for Processing
Under UK GDPR, we must have a valid legal basis for processing your personal data. We rely on the following legal bases:
- Consent: Where you have given us clear consent to process your personal data for a specific purpose, such as accepting analytics cookies.
- Legitimate Interests: Where processing is necessary for our legitimate interests (such as improving our website and services) and your interests and fundamental rights do not override those interests.
- Legal Obligation: Where we need to comply with a legal obligation.
5. How We Use Your Information
We use the information we collect for the following purposes:
- To operate and maintain our website
- To improve and personalise your experience
- To analyse website usage and trends
- To detect and prevent fraud or technical issues
- To comply with legal obligations
6. Third-Party Services
6.1 Google Analytics
We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered is used to create reports about the use of our website. Google's privacy policy is available at: https://policies.google.com/privacy
6.2 Affiliate Partners
Our website contains affiliate links to casino websites. When you click on these links, you may be redirected to third-party websites that have their own privacy policies. We are not responsible for the privacy practices of these third-party sites.
We may receive compensation when you click on affiliate links or sign up at casino websites through our links. This is disclosed on our website via our advertising notice banner and Affiliate Disclosure page.
7. International Data Transfers
Some of our third-party service providers, including Google (for Google Analytics), are based outside of the United Kingdom and European Economic Area. When we transfer your personal data outside of the UK/EEA, we ensure appropriate safeguards are in place:
- Google LLC complies with the EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. Data Privacy Framework
- We rely on standard contractual clauses approved by relevant authorities where applicable
- We only transfer data to countries deemed adequate by the UK government, or to organisations with appropriate safeguards in place
8. Your Rights Under UK GDPR
Under UK data protection law, you have the following rights:
- Right to Access: You can request copies of your personal data
- Right to Rectification: You can request correction of inaccurate data
- Right to Erasure: You can request deletion of your personal data in certain circumstances
- Right to Restrict Processing: You can request restriction of processing in certain circumstances
- Right to Data Portability: You can request transfer of your data to another organisation
- Right to Object: You can object to processing based on legitimate interests
- Right to Withdraw Consent: You can withdraw consent at any time where we rely on consent for processing
To exercise any of these rights, please contact us at privacy@spinary.com. We will respond to your request within one month.
9. Right to Complain
If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the UK supervisory authority:
Information Commissioner's Office (ICO)
Website: ico.org.uk
Helpline: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
We would appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.
10. Cookie Consent
In accordance with UK law (Privacy and Electronic Communications Regulations 2003, as amended), we request your consent before placing non-essential cookies on your device. You can manage your cookie preferences at any time:
- Through our cookie consent banner when you first visit
- By clicking "Manage Cookies" in the website footer
- By adjusting your browser settings
Analytics cookies will only be activated after you provide your consent.
11. Data Retention
We retain automatically collected data for a period of 26 months, after which it is automatically deleted. Cookie consent preferences are stored in your browser and persist until you clear your browser data or update your preferences.
12. Data Security
We implement appropriate technical and organisational security measures to protect your personal information, including:
- SSL/TLS encryption for data in transit
- Regular security assessments
- Access controls and authentication measures
However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.
13. Children's Privacy
Our website is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. The gambling content on this site is strictly for adults aged 18 and over.
14. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date. You are advised to review this Privacy Policy periodically for any changes.
15. Contact Us
If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or have any concerns about how we handle your data, please contact us:
Email: privacy@spinary.com