01 Introduction
This Privacy Policy ("Policy") is issued by Spinwi ("Spinwi", "we", "us", "our") and governs the collection, use, storage, disclosure and protection of personal data obtained from users ("you", "your", "User") of the Spinwi website located at https://spinwi.cam and all associated pages and services (collectively, the "Platform").
Spinwi operates as an online gaming information and entertainment platform. We produce guides, reviews and educational content relating to sports betting, casino products and related gaming topics. We take data protection seriously. This Policy describes precisely what data we collect from you, why we collect it, how we use it and what your rights are in relation to it.
By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy and that you consent to the data practices described herein. If you do not agree with this Policy, you must discontinue use of the Platform immediately.
02 Definitions
The following definitions apply throughout this Privacy Policy:
03 Data We Collect
Spinwi collects personal data through a variety of means depending on how you interact with the Platform. The categories of data we may collect are as follows:
3.1 Data You Provide Directly
When you voluntarily interact with the Platform — for example by creating an account, submitting an enquiry or contacting our support team — you may provide:
- Full name and contact details, including email address.
- Username and password (stored in hashed, encrypted form).
- Country of residence and, where relevant, city of residence within Pakistan (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar).
- Any other information you choose to include in a support query or feedback submission.
3.2 Data Collected Automatically
When you browse the Platform, our systems automatically collect certain technical data, including:
- IP address and approximate geographic location derived from it.
- Browser type, version and operating system.
- Device type and screen resolution.
- Pages visited, time spent on each page and navigation path through the Platform.
- Referring URL (the website or search engine that directed you to the Platform).
- Date and time of each visit.
3.3 Data from Cookies and Tracking Technologies
Spinwi uses cookies and similar tracking technologies to enhance Platform functionality and gather analytical data. Full details of cookies used are set out in Section 7 (Cookies & Tracking) below.
04 Data Processing
Spinwi processes personal data for the following purposes:
| Purpose | Data Used | Basis |
|---|---|---|
| Platform operation — Delivering content, managing accounts and maintaining Platform functionality. | Account data, technical data, usage data | Contract / Legitimate Interest |
| User support — Responding to enquiries, complaints and support requests. | Contact data, correspondence content | Contract / Legitimate Interest |
| Platform analytics — Understanding how users navigate the Platform to improve content quality and usability. | Technical data, usage data, cookie data | Legitimate Interest / Consent |
| Security and fraud prevention — Detecting, investigating and preventing unauthorised access, abuse and fraud. | IP address, account data, technical data | Legitimate Interest / Legal Obligation |
| Legal compliance — Meeting applicable legal obligations, including responding to lawful regulatory or law-enforcement requests. | All categories as required | Legal Obligation |
| Communications — Sending platform updates, policy change notifications and support-related correspondence. | Contact data, account data | Contract / Legitimate Interest |
05 Legal Basis for Processing
Where data protection legislation requires a legal basis for the processing of personal data, Spinwi relies on one or more of the following:
- Contractual necessity — Processing is necessary to perform a contract with you, such as providing access to your registered account.
- Legitimate interests — Processing is necessary for the legitimate interests of Spinwi (such as platform security and analytics), provided those interests are not overridden by your privacy rights.
- Consent — You have given clear consent, for example by accepting non-essential cookies. You may withdraw consent at any time.
- Legal obligation — Processing is necessary to comply with a legal obligation binding on Spinwi.
06 Data Sharing
Spinwi does not sell, rent or trade your personal data. We may share data with carefully selected third parties only in the following circumstances:
6.1 Service Providers and Data Processors
We engage trusted third-party service providers to assist with the operation of the Platform. These may include web hosting providers, analytics platforms and email delivery services. All such providers are bound by contractual data processing agreements requiring them to process data only on our instructions and to implement appropriate security measures.
6.2 Legal and Regulatory Disclosures
We may disclose personal data to government authorities, regulators or law enforcement agencies where required to do so by law or in response to a valid legal process. We will, where legally permissible, notify you of such disclosures.
6.3 Business Transfers
In the event of a merger, acquisition, sale of assets or restructuring of the Spinwi business, personal data held by the Platform may be transferred to the acquiring entity. We will provide prior notice of any such transfer and ensure that the recipient applies equivalent data protection standards.
07 Cookies & Tracking Technologies
Cookies are small text files stored on your device when you visit the Platform. They help us recognise returning users, remember preferences and gather anonymous usage statistics. We use the following categories of cookies:
| Type | Purpose | Duration |
|---|---|---|
| Required for the Platform to function correctly. Includes session management and security tokens. Cannot be disabled. | Session / Up to 12 months | |
| Collects anonymised data about how visitors use the Platform — pages visited, time on site, navigation paths — to help us improve content and usability. Requires your consent. | Up to 24 months | |
| Remembers your preferences (such as display settings) to personalise your experience. Requires your consent. | Up to 12 months |
You may control and manage cookie preferences through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies or receive notifications before a cookie is set. Please note that disabling essential cookies may impair Platform functionality.
08 Data Retention
Spinwi retains 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 data — Retained for the duration of your account and for a reasonable period thereafter to resolve any outstanding issues, up to a maximum of 3 years from account closure.
- Support correspondence — Retained for up to 2 years from the date of last correspondence.
- Analytics data — Retained in anonymised or aggregated form for up to 24 months.
- Legal compliance records — Retained for the period required by applicable law, which may extend beyond the above periods.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to any individual.
09 Data Security
Spinwi implements technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:
- Transmission of data between your browser and the Platform via TLS/SSL encryption (HTTPS).
- Storage of passwords in hashed, salted form — we do not retain passwords in plain text.
- Access controls limiting who within the Spinwi team can access personal data, on a need-to-know basis.
- Regular security reviews of Platform infrastructure and third-party service provider arrangements.
While we take commercially reasonable precautions, no internet-based system can guarantee absolute security. You are responsible for maintaining the confidentiality of your login credentials and for notifying us promptly if you suspect any unauthorised access to your account.
10 User Rights
Subject to applicable data protection law, you may have the following rights in relation to your personal data held by Spinwi:
Right of Access
You may request a copy of the personal data we hold about you, together with information about how it is processed.
Right to Rectification
You may request correction of any inaccurate or incomplete personal data we hold about you.
Right to Erasure
You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to legal retention obligations.
Right to Restriction
You may request that we restrict the processing of your data in certain circumstances, such as where you contest its accuracy.
Right to Portability
Where processing is based on your consent or a contract, you may request a structured, machine-readable copy of the personal data you provided to us.
Right to Object
You may object to processing based on legitimate interests, including profiling. We will cease processing unless we can demonstrate compelling legitimate grounds that override your rights.
To exercise any of the above rights, please contact us using the details in Section 14 (Contact Us) of this Policy. We will respond to verified requests within 30 days. We may ask you to verify your identity before processing any request relating to personal data.
11 Children's Privacy
The Spinwi Platform is intended solely for adults aged 18 years or older, or the higher minimum age required by the operator or licence jurisdiction applicable to any gaming activity. We do not knowingly collect personal data from individuals under the required minimum age.
If we become aware that personal data has been collected from an individual below the minimum age threshold, we will take immediate steps to delete that data and terminate the associated account. If you believe a minor has provided personal data to us, please contact us immediately at the address provided in Section 14.
12 International Data Transfers
Spinwi operates internationally and your personal data may be processed in countries outside your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction. Where such transfers occur, we implement appropriate safeguards to protect your data, including:
- Standard contractual clauses approved by relevant data protection authorities.
- Transfers only to jurisdictions with an adequacy decision where applicable.
- Contractual data processing agreements with all service providers.
Users in Pakistan should be aware that Pakistan's data protection legislation is evolving. Spinwi does not rely on Pakistani regulatory frameworks as the basis for international data transfers. Your data rights under this Policy are defined by the laws of the jurisdiction governing Spinwi's operations.
13 Policy Amendments
Spinwi reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will update the "Last Reviewed" date displayed at the top of this page and, where appropriate, notify registered users of the change by email or through a prominent notice on the Platform.
Your continued use of the Platform following publication of a revised Privacy Policy constitutes your acceptance of those changes. We encourage you to review this page periodically, particularly if you are an active user of the Platform.
14 Contact Us
If you have any questions, requests or complaints relating to this Privacy Policy or the way in which Spinwi handles your personal data, please contact our team using the details below. Note that the email address is provided as plain text only and is not a clickable link.
Spinwi Privacy Team
Email: [email protected]
Subject line: "Privacy Request — [Your Name]"
Response time: within 30 days of a verified request
Language: English (Urdu assistance available on request)
When submitting a data rights request, please include sufficient information to allow us to verify your identity and locate your records. We will process your request in accordance with the timelines described in this Policy.
For general platform queries, please visit our FAQ page. For information about platform terms and user obligations, please refer to our Terms & Conditions.