Spinlander Privacy Policy

Spinlander collects personal data that users provide directly during registration, account management, and use of its services. This information is gathered to deliver a functional, secure, and compliant platform experience.

Types of Personal Data Collected

The following categories of personal information may be collected:

• Full name and date of birth;
• Email address and contact details;
• Payment and billing information;
• Government-issued identification documents (where required for verification);
• Device data, IP address, and browsing behaviour on the platform.

Technical and Organizational Protection Measures

Spinlander applies industry-standard security protocols to protect all personal data, including:

• Encryption of sensitive data in transit and at rest;
• Restricted internal access to personal information on a need-to-know basis;
• Regular security assessments and system monitoring;
• Compliance with data breach notification obligations under Canadian law.

User Rights Under Canadian Privacy Law

In accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial legislation, users have the right to:

• Access the personal data held about them;
• Request correction of inaccurate or incomplete information;
• Request deletion of personal data where retention is no longer legally required;
• Withdraw consent for non-essential data processing.

All requests related to personal data rights may be submitted through the platform’s designated support channels.

Personal data collected by Spinlander is used exclusively for lawful, defined purposes. The platform does not process user information beyond the scope described in this document.

Purposes of Data Processing

Collected information is used for the following purposes:

• Account creation, verification, and ongoing account management;
• Processing deposits, withdrawals, and financial transactions;
• Delivering and improving platform services and user experience;
• Sending account-related communications and, where consent is given, promotional content;
• Conducting analytics to understand usage patterns and optimize platform performance;
• Fulfilling legal and regulatory compliance obligations, including anti-money laundering and responsible gambling requirements.

Lawful Basis for Processing

All data processing activities are carried out on one or more of the following lawful bases:

• Explicit user consent obtained at the time of collection;
• Contractual necessity, where processing is required to fulfil the terms of service;
• Legal obligation, where applicable under Canadian federal or provincial law.

Users will not receive marketing communications without having provided clear consent. Consent for marketing may be withdrawn at any time through account settings or by contacting support.

Users retain ongoing rights over their personal data at all times. Spinlander provides accessible procedures for exercising these rights.

Accessing Personal Data

A registered user may request a copy of the personal data held on their account by contacting the support team. Requests are handled in a timely manner and in compliance with applicable Canadian privacy legislation.

Correcting Personal Data

If any personal information on file is inaccurate or outdated, users may request a correction through the account settings or by reaching out to the support team directly. Corrections are applied without undue delay upon verification.

Deleting Personal Data

Users may request the deletion of their personal data where it is no longer required for the purposes for which it was collected, subject to any legal retention obligations. Certain data may be retained as required by anti-money laundering regulations or other applicable laws.

Consent to Security and Payment Processing

By using Spinlander’s platform, users consent to the processing of their identification and payment data by authorized third-party service providers. These providers conduct security checks and facilitate financial transactions on behalf of the platform. All third-party processors are contractually required to handle personal data in a manner consistent with this Privacy Policy and Canadian privacy standards.

Spinlander’s platform is strictly intended for individuals who are 18 years of age or older. Access to online gambling services by minors is prohibited in all jurisdictions served by the platform.

Age Verification Limitations

Spinlander employs age verification procedures during the registration process; however, the platform cannot independently confirm the age of every user without the submission of valid government-issued identification documents. Users are required to provide accurate information regarding their age at the time of registration.

Handling of a Minor’s Personal Data

If a parent or legal guardian becomes aware that a minor has accessed the platform and provided personal information without authorization, they may contact Spinlander’s support team to request the deletion of that data. Upon verification of the request, all personal data associated with the minor’s account will be removed from the platform’s systems in accordance with applicable privacy obligations.

Spinlander operates through a network of licensed partners and service providers who may be located outside of Canada. As a result, personal data collected by the platform may be transferred to, stored in, or processed in jurisdictions other than the user’s country of residence.

Consent to Cross-Border Data Processing

By accessing and using Spinlander’s platform, users acknowledge and consent to the transfer of their personal data to countries where the platform’s partners and service providers operate. These countries may have data protection laws that differ from those applicable in Canada.

Confidentiality Obligations of Partners

All third-party partners and processors engaged by Spinlander are required to maintain appropriate confidentiality and data security standards. Contractual agreements with these parties include provisions that ensure personal data is handled responsibly and in a manner consistent with the principles set out in this Privacy Policy.

Certain provisions within this Privacy Policy function as a legal disclaimer that may alter or limit the scope and effects of specific rules described elsewhere in the document. Users should be aware that these provisions carry legal significance and form part of the binding agreement between the user and Spinlander.

Applicability of the Disclaimer

The legal disclaimer contained within this Privacy Policy takes effect at the moment a user accepts the policy. Acceptance occurs through one of the following actions:

• Digital signature or acknowledgment during account registration;
• Checking an acceptance box or clicking a confirmation button on the platform;
• Continued use of the platform following notification of a policy update.

By completing any of the above actions, users confirm that they have read, understood, and agreed to the terms of this Privacy Policy, including all disclaimer provisions.

Cookies are small text files stored on a user’s device when they access a website. Spinlander uses cookies to support the functionality, performance, and continuous improvement of its platform.

Purposes of Cookie Use

Cookies are deployed on the Spinlander platform for the following purposes:

• Collecting statistical data on platform usage and traffic patterns;
• Analysing user behaviour to identify areas for service improvement;
• Personalising the platform experience based on individual user preferences;
• Supporting the delivery of relevant content and account features.

Cookie Retention Period

Cookies stored on a user’s device through interaction with the Spinlander platform are retained for a period of up to one year from the date of their placement. Users may manage or disable cookies through their browser settings at any time; however, doing so may affect the functionality of certain platform features.

By accessing or using Spinlander’s platform, users signify their full and unconditional acceptance of the terms set out in this Privacy Policy. This acceptance covers all data collection, processing, storage, and disclosure practices described herein.

Current Version

The version of the Privacy Policy currently published on the platform is the version in force. In the event of any discrepancy between previously communicated versions and the current document, the current published version prevails in all respects. Users are encouraged to review this document periodically to remain informed of any updates. Continued use of the platform following the publication of any amendments constitutes acceptance of the revised terms.

Spinlander may share personal data with third parties under specific and defined circumstances. All such disclosures are conducted in accordance with applicable Canadian privacy legislation and the terms of this Privacy Policy.

Circumstances Under Which Data May Be Shared

Personal data may be disclosed to third parties in the following situations:

• To comply with a legal obligation, court order, or regulatory requirement;
• In connection with the investigation or resolution of a dispute involving the user's account;
• Pursuant to a contractual agreement with a service provider or business partner required to deliver platform services.

Third-Party Partners

Where applicable, the identities of third-party recipients are listed on the platform. In cases where a specific recipient is not named, users will be informed of the purpose and scope of any data disclosure prior to or at the time of sharing.

Consent Through Data Submission

By providing personal data on the Spinlander platform, users consent to the potential disclosure of that information to authorized third parties as described in this section. Users who do not consent to such sharing should refrain from submitting personal information beyond what is strictly required for platform access.

The Spinlander platform may contain hyperlinks to third-party websites that are not owned, operated, or controlled by Spinlander. These external sites maintain their own independent privacy policies and data handling practices.

Spinlander’s Limited Responsibility

Spinlander does not assume responsibility for the privacy practices, content, or data collection activities of any third-party websites accessed through links on the platform. The presence of a link does not constitute an endorsement of the linked site or its privacy standards.

User Caution When Visiting External Sites

Users are advised to exercise caution and review the applicable privacy policy of any external website before providing personal information. Personal data submitted to third-party sites is governed solely by the policies of those sites and is beyond the control of Spinlander.