This Privacy Policy explains how Spinomera (“we”, “us”, “our”) collects, uses, stores, shares, and protects personal data when you access or use the Spinomera platform (the “Platform”).
Spinomera is an entertainment-only social casino. We do not offer real-money gambling, do not permit cash withdrawals, and virtual currency has no real-world monetary value.
We are committed to protecting your privacy and processing personal data transparently, lawfully, and securely in accordance with the UK General Data Protection Regulation (“UK GDPR”), the EU GDPR where applicable, and the Data Protection Act 2018.
By accessing or using the Platform, you confirm that you have read and understood this Privacy Policy.
1. Who We Are
Spinomera operates the Platform and determines how and why your personal data is processed.
- Data Controller: Spinomera
- Contact email: privacy@spinomera.com
2. Scope of This Policy
This Policy applies to:
- The Spinomera website
- Any associated web or mobile applications
- Customer support and communications
- Marketing and analytics activities related to the Platform
It does not apply to third-party websites or services linked from the Platform.
3. Personal Data We Collect
3.1 Information You Provide
- Name or chosen username
- Email address
- Account login credentials
- Date of birth or age confirmation
- Customer support messages
- Preferences and settings
- Purchase information relating to virtual items or subscriptions
3.2 Information Collected Automatically
- IP address
- Device identifiers
- Browser type and operating system
- Log files and timestamps
- Gameplay data, XP, achievements, and in-platform activity
- Referring URLs
- Cookie and tracking data
3.3 Payment Data
Payments are processed by third-party payment providers. We do not store full card numbers or sensitive payment credentials. We may receive transaction confirmations, billing country, and payment status.
4. How We Use Personal Data
We use personal data only where necessary and proportionate, including to:
- Create and manage user accounts
- Provide and operate the Platform
- Deliver virtual currency, items, and subscriptions
- Personalise gameplay and progression
- Communicate service notices and updates
- Provide customer support
- Detect fraud, abuse, and security risks
- Monitor platform stability and performance
- Analyse usage to improve features and user experience
- Comply with legal, regulatory, and contractual obligations
We do not sell personal data.
5. Legal Bases for Processing
We rely on the following lawful bases:
- Performance of a contract - to provide the Platform
- Legitimate interests - security, analytics, fraud prevention, service improvement
- Legal obligations - compliance with law and regulation
- Consent - where required (e.g. marketing communications, non-essential cookies)
6. Analytics & Performance Monitoring
We use analytics and performance monitoring tools to understand how users interact with the Platform and to improve reliability, security, and user experience.
Analytics may collect:
- Pages viewed and features used
- Session duration and interaction patterns
- Device type, browser, and operating system
- Approximate location derived from IP address
- Error logs and performance metrics
Where possible, analytics data is aggregated or pseudonymised and is not used to directly identify individuals.
7. Cookies & Similar Technologies
We use cookies and similar technologies to:
- Enable core platform functionality
- Maintain user sessions
- Remember preferences
- Analyse usage and performance
- Improve security
Cookies may be classified as essential or non-essential. Where required by law, non-essential cookies are used only with consent. You can manage cookie preferences via your browser or any cookie controls we provide.
8. Marketing Communications
We may send service-related communications such as security alerts or account notices.
Marketing communications are sent only where you have opted in and you may unsubscribe at any time using the link provided or by contacting us.
9. Sharing of Personal Data
We may share personal data with trusted third parties only where necessary, including:
- Hosting and cloud infrastructure providers
- Analytics and performance monitoring providers
- Payment processors
- Customer support platforms
- Security, fraud prevention, and abuse detection services
- Legal, regulatory, or law-enforcement authorities where required
All third parties are bound by contractual obligations to protect personal data and process it only on our instructions.
10. International Data Transfers
Where personal data is transferred outside the UK or EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or equivalent legal mechanisms.
11. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes outlined in this Policy or to meet legal obligations.
Accounts that remain inactive for extended periods may be anonymised or deleted in accordance with our retention practices.
12. Your Rights
You have the right to:
- Access your personal data
- Rectify inaccurate or incomplete data
- Request erasure
- Restrict processing
- Object to processing
- Withdraw consent at any time
- Data portability
- Lodge a complaint with the Information Commissioner’s Office (ICO) or another supervisory authority
Requests can be made by contacting privacy@spinomera.com.
13. Children & Age Restrictions
The Platform is intended for users aged 18 and over.
We do not knowingly collect personal data from minors. If we become aware that a minor has provided personal data, we will take steps to delete it promptly.
14. Security Measures
We implement appropriate technical and organisational measures to protect personal data, including encryption, access controls, secure hosting, and monitoring.
No system can be guaranteed to be completely secure, and users acknowledge this risk.
15. Automated Decision-Making
We do not use automated decision-making or profiling that produces legal or similarly significant effects on users.
16. Changes to This Policy
We may update this Privacy Policy from time to time. Any material changes will be communicated via the Platform or by email where appropriate.
Continued use of the Platform after updates constitutes acceptance of the revised Policy.
17. Contact
For privacy-related enquiries or requests:
Email: privacy@spinomera.com