Spinova Zones — Privacy Policy
Version: 7.0
Published: 25.10.2025
At Spinova Zones (“Spinova,” “we,” “us,” or “our”), we respect your privacy and the trust you place in us. This Privacy Policy explains what we collect, why we collect it, how we use/share it, and the choices you have. It applies to SpinovaZones.com (including subdomains, successor sites, and any apps that link to this policy) and services offered through it (the “Website”).
By using the Website, you agree to this Privacy Policy. If you do not agree, please discontinue use.
1) Scope & What’s Not Covered
Covered:
- Information collected on the Website;
- Emails, texts, live chat, and other electronic messages between you and us;
- Mobile/desktop apps that provide non-browser interactions with the Website;
- Interactions with our ads or apps on third-party services that link to this policy.
Not covered:
- Information collected offline or via channels not listed above;
- Information collected by third parties (including sites or apps that may link to or be accessible from the Website).
2) Data We Collect & Retention
We collect personal information, anonymous information, and may derive aggregate information (see Definitions).
Examples of data we may collect:
- Contact details: name, email, postal address, phone.
- Profile/demographics: age (or age range), gender, avatar.
- Account credentials: username, password, profile image.
- Transactions & support: purchase/redemption details (if applicable), billing/shipping data, communications with Support.
- Communications: messages via email, chat, text, or similar channels.
- Third-party signals: data from platforms (e.g., social networks) about your use of or interest in our services.
- Location data: device location or IP-based location, where permitted by law.
- Device/usage data: pages viewed, session times, frequency, referral sources, preferences, device/OS/browser, IP, identifiers.
- Regulatory/KYC (if applicable): government-issued IDs or similar information required by law to verify identity or satisfy AML/CTF or tax obligations.
Retention. We keep data only as long as needed for the purposes below or as required by law. For UK residents, categories (as defined under UK law) processed in the last 12 months and intended retention:
- A. Identifiers (name, address, email, phone, account name, IP, government IDs): Yes — 3 years (account administration, legal/operational needs).
- B. Personal & financial info (bank/card details, limited employment/education if provided for verification): Yes — 3 years (contract, audits, legal compliance).
- C. Special category data (processed only where lawful, e.g., explicit consent/legal requirement): Possible — 3 years.
- D. Commercial info (products/services purchased/considered; preferences): Yes — 3 years (analytics, CRM, improvement).
- E. Biometric/genetic: No.
- F. Online activity (browsing/search history, ad interactions, app usage): Yes — 3 years (performance/experience).
- G. Location data: Yes — 3 years (features/logistics).
- H. Sensory data: No.
- I. Employment/professional: No.
- J. Education data: No.
- K. Inferences/profiles: No (or used only for personalization/service improvement; 3 years).
3) How We Collect Data
- Directly from you: registration, purchases, forms, surveys, promotions, customer support (phone/video may be recorded for training, quality, compliance—continuing the call is your consent).
- Automatically: cookies, pixels, SDKs, APIs, mobile identifiers, logs, analytics (see Section 5).
- From third parties: verification services and trusted sources used to validate or enrich data (e.g., address/identity verification).
4) How We Use Data
- Provide & manage services: account setup and maintenance, fraud/abuse checks.
- Improve support & services: respond to requests; use feedback to enhance features.
- Process payments/redemptions: fulfill orders; meet KYC/AML (“source of funds” where relevant).
- Personalize & analyze: aggregate insights to understand Website use.
- Communicate with you: account notices, features, promotions, surveys, contests (manage preferences at any time).
- Send important notices: transactional or legal updates (you may not be able to opt out of strictly necessary notices).
- Legal compliance: responsible play assessments, tax, anti-fraud/AML, enforcement of terms/legal processes.
- Alternative dispute resolution: share necessary data with an ADR partner to resolve disputes.
We do not use automated decision-making within the meaning of European data-protection laws.
5) Cookies & Similar Technologies
We and partners use cookies, pixels/web beacons, mobile IDs, and event tags to remember preferences, measure engagement, improve performance, and deliver/measure ads. You can block/delete cookies via your browser; some features may not work properly without them.
We may participate in interest-based advertising using third-party tools across sites/apps. Those third parties control their own tracking technologies; consult their policies for details.
6) Your Rights & Choices
Subject to law, you may have rights to access, rectify, erase, restrict, object, and portability, and to withdraw consent where processing is based on consent. These rights may be limited by legal obligations.
- Direct marketing: You can object at any time to direct marketing (including related profiling).
- Opt-out signals / Global Privacy Control: You can limit non-essential data collection via browser/device settings; functionality may be affected.
- Interest-based ads: Use your browser/device settings or regional opt-out tools where available.
UK GDPR (and Data Protection Act 2018) — How to submit a request
Email **[email protected]** (or use the Help/Contact form) and provide:
- Enough information to verify your identity (we may ask for additional verification);
- A clear description of your request (access, correction, deletion, restriction, objection, portability).
We aim to respond within one month. For complex/multiple requests, we may extend by up to two months and will notify you.
- Authorized representatives: You may appoint one with written authorization; we may request evidence.
- Fees: Not charged unless requests are excessive/repetitive/manifestly unfounded.
- Appeals: Where available, email **[email protected]; we’ll respond within 45 days** with further options if you disagree.
Registered users can update certain account details in profile settings. We do not discriminate for exercising your rights.
Data deletion requests. For security, we require identity verification before processing account deletion.
7) Security
We implement physical, technical, and organizational safeguards (including encryption and layered access controls) to protect data against unauthorized access, alteration, disclosure, or destruction. No method of transmission or storage is 100% secure; use the Website at your own risk and keep your credentials confidential.
8) Sharing Your Information
We do not sell, trade, or rent personal information. We share data only as described:
- Within Spinova group: with affiliates for the purposes in this policy (see Transfers).
- Service providers: hosting, storage, analytics, payments, KYC/AML, marketing support—bound to use data only as instructed or as required by law.
- With your consent/direction: where you ask us to share.
- Regulatory/legal: comply with lawful requests, processes, and regulatory inquiries; protect rights/users; enforce terms; detect/prevent fraud/illegal activity.
- Corporate transactions: mergers, acquisitions, restructurings, or asset transfers.
- Financial institutions/regulators: to complete transactions or meet AML/CTF or similar obligations.
Categories disclosed in past 12 months (UK GDPR):
- A. Identifiers: merchants/verification providers (identity/eligibility).
- B. Contact/Account: merchants/verification providers (transactions/verification).
- C. Protected characteristics: verification providers (where legally required).
- D. Commercial info: merchants (to process purchases/redemptions).
- E–K: Not collected or not disclosed as stated above.
Aggregated/de-identified data may be shared for insights that cannot reasonably identify you.
9) International Transfers
We operate internationally. Personal data may be processed in the EU or other countries where we or our providers operate. Where required, we use appropriate safeguards (e.g., Standard Contractual Clauses) or other lawful mechanisms to protect your data.
10) Children’s Privacy
Our services are for individuals 18+. We do not knowingly collect data from anyone under 18. If we learn that we have collected such data, we will delete it. If you believe a minor provided data to us, contact **[email protected]**.
11) Do-Not-Track
There is no industry consensus on responding to browser “Do-Not-Track” signals; the Website does not act on them at this time. We will reassess if standards emerge.
12) Changes to This Policy
We may update this Policy to reflect changes in practices or legal requirements. Where required, we will notify you and, if necessary, obtain consent. Updates are effective when posted on the Website. Please review periodically.
13) Definitions
- Personal information: Data that identifies or can reasonably be linked to a specific person (e.g., name, address, email, phone). When anonymous data is linked to personal data, it is treated as personal information.
- Anonymous information: Data that cannot reasonably identify an individual.
- Aggregate information: Compiled statistics about groups or categories that do not identify individuals.
14) Contacting You via Email or Text
By providing contact details, you confirm they are accurate and that you are the subscriber/authorized user. You consent to receive service-related communications (including automated or prerecorded messages) about: (i) this Policy and related terms; (ii) your account/transactions; and (iii) Spinova updates/promotions. Carrier charges may apply. You can adjust marketing preferences at any time (see Your Rights & Choices).
15) Contact Us
Questions about this Privacy Policy or your data?
- Email (Privacy): **[email protected]**
- Support: **[email protected]**
- Website: SpinovaZones.com (Help/Contact form)
Please include your place of residence and a brief description of your request.