SpinBetter Partners will only process your personal data upon your explicit consent (hereinafter referred to as “Consent”).

Your Consent may be granted either in written form or implicitly through your actions on our website, by you or by your authorized representative.

WRITTEN CONSENT

A written Consent must include the following details:

1. Full name, residential address, identification document number, date of issue, and issuing authority of the personal data subject; or, in the case of an authorized representative, the same details along with the document confirming their authority (e.g., notarized power of attorney);

2. The postal or email address of SpinBetter Partners receiving the Consent, and the purposes of data processing;

3. A list of personal data to be processed;

4. The name and address of any third party that may be delegated data processing by SpinBetter Partners;

5. The types of data processing permitted and a general description of processing methods;

6. The validity period of the Consent and instructions for its revocation;

7. Signature of the data subject.

Written consent must be submitted to us via email and is considered received only upon our written confirmation in response.

IMPLIED CONSENT THROUGH ACTION

Consent may also be implied through behavior that clearly indicates an intent to establish a legal relationship with SpinBetter Partners—for example, by completing the registration form on our website.

Cases Where Consent Is Not Required:

Your personal data may be processed without prior consent in the following cases:

1. When required to comply with international agreements or local laws, or to fulfill legally mandated responsibilities and powers;

2. When required for judicial purposes or to execute legal decisions or orders from authorities in accordance with local law;

3. When necessary to protect your life, health, or other vital interests;

4. When necessary for the exercise of legal rights or interests of SpinBetter Partners or third parties, provided this does not infringe upon your rights and freedoms;

5. When used for statistical or research purposes, provided the data is anonymized and not used for marketing;

6. When the data has been made publicly available by you;

7. When data must be published or disclosed by law in accordance with local legal requirements.

We collect and process data that may be used to identify you personally, including but not limited to:

• First and last name
• Date of birth
• Credit card or bank account information
• Payment details and transaction history
• Residential or other physical address
• Email address
• Phone number
• Messenger ID you use to contact us

You may be asked to provide Personal Data when using our website or services and when registering an account.

This information is collected, processed, and stored on our servers in accordance with the legal requirements of your jurisdiction.

Technical Data

When you use our services, our servers automatically log your activity. This includes certain administrative and traffic-related information such as:

• IP address
• Access time
• Access date
• Visited web pages
• Language preferences
• Software crash reports
• Type of browser used

This information is necessary to provide high-quality service. We never collect Personal Data without your knowledge.

We may automatically collect certain data and receive Personal Data that you voluntarily provide through your use of our services, communications, and interactions on the SpinBetter Partners website.

We may also receive Personal Data from online vendors, service providers, or customer lists lawfully acquired from third-party suppliers.

In addition, we may use the services of third-party providers to support online transactions and maintain user accounts.

We will have access to any information you provide to such vendors and third-party e-commerce services, and we will use the Personal Data in accordance with this Policy.

This information will be disclosed to third parties outside the company only as permitted by this Policy and the laws of your country.

We use the Personal Data you provide to us to deliver our services, including informational services, customer support, security assurance, identification and verification, processing of online transactions, assistance with third-party promotional campaigns aligned with specific business requirements, and for any other purposes related to the operation of our Services.

Accordingly, in the course of providing services, we may share your personal data with our partners (including any third parties with whom you have a data-sharing agreement).

Your personal data may also be used by us to provide you with:

1. Promotional offers and information about our products and services;

2. Promotional offers and information about the products and services of our partners, aimed at broadening the range of Services available to you and improving the overall customer experience.

From time to time, we may request information from you through surveys or contests. Participation in these surveys or contests is entirely voluntary, and you always have the choice whether or not to disclose your personal information.

The requested information may include contact information (such as name, mailing address, phone number) and geographic data (such as zip code or mailing address), as well as age.

By participating in any contest or accepting a prize from us, you agree that we may use your name for promotional purposes without additional compensation, except where prohibited by law.

We may disclose information about you to companies, organizations, or individuals not affiliated with SpinBetter Partners if you have given us consent to do so.

We may also disclose your Personal Data if required by law, or if it is found that you have deceived or attempted to deceive us or any other user in any way (e.g., game manipulation, payment fraud, etc.), or if we believe that such disclosure is necessary to:

1. Comply with any legal obligation or process related to us, any of our sites, or any of our services, or where we are otherwise legally required to do so;

2. Protect our rights or property;

3. Protect our users or the public.

You can opt out of receiving any promotional messages by:

1. Adjusting your account settings;

2. Responding to the promotional message you received from us;

3. Sending an email or contacting customer support at any time.

Your full rights regarding your Personal Data include:

1. The right to withdraw your consent to data processing at any time;

2. The right to object to the processing of your data. If we process your data on the basis of our legitimate interests (e.g., direct marketing or market research), you can object. We will assess your request and, unless we have compelling legal grounds (such as public interest or inability to identify you), we will cease such processing;

3. The right to be informed about the data we hold about you, how we obtained it, and how long we intend to keep it;

4. The right to review and correct your personal data if it is inaccurate, incomplete, or outdated;

5. The right to restrict the processing of your data. If you dispute the accuracy of your data, believe it is being processed unlawfully, or want to object to the processing, you can temporarily halt the processing to verify the circumstances. During this time, we will not process your data for any purpose other than storage or legal compliance until the issue is resolved;

6. The right to request deletion/destruction of your personal data (right to be forgotten). Please note that deleting your data may impact your use of our Services or lead to termination of our relationship if the data was essential for service delivery;

7. The right to transfer your data to another organization (right to data portability). This applies when we process your data based on your consent or in the context of a contract or contract negotiations, and the processing is automated;

8. The right to file a complaint with a supervisory authority.

You may exercise these rights free of charge by contacting us via the email address provided above. In some cases, we may ask you to verify your identity before acting on your request.

We may also transfer your Personal Data if required to do so by law.

INFORMATION STORED ON YOUR DEVICE

When you use our services, we may, with your permission, store certain information on your device. This information is called cookies. These are small text files saved on your device to remember your preferences when using our services, visiting websites, and browsing online pages.

We also use local objects or “flash cookies.” These are similar to browser cookies and help retain your preferences during site visits, as well as store data required for multimedia playback.

Neither browser cookies nor flash cookies provide us with access to your device or the information stored on it.

They are used solely for analytical purposes, to track your usage of our services, and to improve quality and relevance of the content displayed to you.

TYPES OF COOKIES WE USE:

1. Necessary cookies – enable navigation on the site and the use of its features (e.g., access to secure areas or conducting transactions). Without these, the website cannot function properly.

2. Registration cookies – contain information collected during the registration process. They help personalize services and analyze your preferences and behavior to enhance your user experience.

3. Session cookies – stored only during your current session. They are deleted once the browser is closed.

4. Persistent cookies – remain on your device beyond a single session. They are used to remember your preferences.

5. Analytical cookies – allow us to count users and analyze on-site behavior, helping us improve functionality and navigation.

COOKIE MANAGEMENT

You may accept or reject the use of cookies at any time. Most browsers automatically accept cookies, but you can modify your browser settings to:

1. Delete all cookies

2. Block all cookies

3. Allow all cookies

4. Block third-party cookies

5. Clear cookies upon closing the browser

6. Use “incognito” mode

7. Install plugins for advanced cookie management

Useful links for cookie settings:

• Internet Explorer: https://support.microsoft.com/kb/278835
• Chrome: https://support.google.com/accounts/answer/32050
• Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
• Safari: https://support.apple.com/kb/PH21411?locale=en_US
• Opera: https://help.opera.com/en/latest/web-preferences/#cookies

FLASH COOKIES

To manage flash cookies, you can adjust settings via the Flash Player settings manager. Please note: if you block all cookies, certain site features may become unavailable (e.g., saving your interface language preferences).

We reserve the right to conduct security checks at any time to verify registration data accuracy, proper use of our services, and compliance of financial transactions with applicable laws and our terms.

By using our services, you agree to this Policy and authorize us to use the data you provide for such checks, including interacting with external databases.

Security checks may include financial reporting and identity verification through external resources.

We understand the importance of security and employ necessary methods to maintain the confidentiality, integrity, and availability of information. All Personal Data that we receive directly from you is stored in an encrypted and password-protected database located on our secure network protected by up-to-date firewall software.

Our services support SSL version 3 with 128-bit encryption.

We also ensure that our subsidiaries, agents, partners, affiliates, and vendors apply similarly adequate security measures.

However, the transmission of information over the Internet is generally not entirely secure, and we cannot guarantee the security of your data while it is in transit.

SpinBetter Partners has all appropriate security procedures in place to protect your data once it is received.

Our services and website are not intended for individuals under the age of 18 or the age of majority in your jurisdiction.

Anyone providing information to us through our services confirms that they are at least eighteen (18) years old (or the applicable age of majority in their country).

Our policy includes identifying attempts by minors to access our services, which may require additional security review.

If we become aware that a minor has attempted to provide or has provided us with Personal Data through our services, we will not accept it and will delete such information from our databases.

Personal Data is stored for the duration of the business relationship between us or until a request for deletion is received.

Your information will be deleted, anonymized, or pseudonymized as soon as it is no longer necessary for the operation of our website.

Personal information collected by us may be stored and processed in any country where we or our affiliates, vendors, partners, or agents provide gaming services and platform functionalities.

By using our services, you expressly consent to the transfer of your information outside your country (including to countries not deemed to have adequate data protection laws).

Nevertheless, we take all necessary steps to ensure our agents, partners, affiliates, and vendors, regardless of location, comply with our privacy standards and this Privacy Policy in particular.

We cannot ensure the protection of any information you provide to third-party websites that link to our services, or any information collected by third parties participating in our affiliate programs (if applicable) or otherwise, as these websites and services are not owned or operated by us.

Any information collected by such third parties is governed by their own Privacy Policies, if available.

If you have any questions about this Privacy Policy or wish to exercise any of your rights as outlined in Section 6 of this Policy, please contact us at: [email protected]