Privacy Policy

1. Data Controller

SpinsRoyaler, located at Kauppakatu 15, 00100 Helsinki, New Zealand, is the data controller for personal data processed through our social casino platform.

2. Lawful Bases for Processing

We process personal data based on the following lawful bases under GDPR:

• Consent: For optional analytics and marketing cookies
• Contract: To provide our social casino services
• Legitimate Interest: For platform security and fraud prevention
• Legal Obligation: To comply with Finnish and EU regulations

3. Data Categories We Collect

Account Information

• Email address (if registration is implemented)
• Age verification status
• Account preferences and settings

Usage Data

• Game activity and progress
• Virtual credit balances and transactions
• Platform interaction patterns
• Session duration and frequency

Technical Data

• IP address and location data
• Device and browser information
• Cookie and tracking data (with consent)

4. Data Retention Periods

We retain personal data for the following periods:

• Account data: For the duration of account activity plus 3 years
• Game activity: 2 years from last activity
• Technical logs: 12 months
• Marketing data: Until consent is withdrawn or 2 years of inactivity

5. Your Rights Under GDPR

As a data subject, you have the following rights:

Right of Access

Request a copy of personal data we process about you, including information about processing purposes and recipients.

Right to Rectification

Request correction of inaccurate or incomplete personal data.

Right to Erasure (Right to be Forgotten)

Request deletion of your personal data when processing is no longer necessary or lawful.

Right to Data Portability

Receive your personal data in a structured, commonly used format for transfer to another service.

Right to Object

Object to processing based on legitimate interests or for direct marketing purposes.

Right to Restrict Processing

Request limitation of processing in specific circumstances.

6. Data Protection Officer

For data protection inquiries, please contact our Data Protection Officer at:

Email: dpo@spinsroyaler.com
Address: SpinsRoyaler DPO, Kauppakatu 15, 00100 Helsinki, New Zealand

7. Third-Party Processors

We may share data with the following types of processors:

• Cloud hosting providers: For platform infrastructure
• Analytics services: For usage analysis (with consent)
• Customer support tools: For user assistance
• Security services: For fraud prevention and platform protection

All processors are bound by data processing agreements and GDPR compliance requirements.

8. No Sale of Personal Data

We do not sell, rent, or commercially distribute personal data to third parties. Data sharing only occurs as described in this privacy policy for service provision and legal compliance.

9. Protection of Minors

SpinsRoyaler is exclusively for users 18 years and older. We do not knowingly collect personal data from minors. If we discover that personal data from a minor has been collected, we will delete it immediately.

10. International Data Transfers

If data is transferred outside the EU/EEA, we ensure adequate protection through:

• European Commission adequacy decisions
• Standard Contractual Clauses
• Other appropriate safeguards under GDPR

11. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction.

12. Contact for Privacy Matters

For questions about this privacy policy or to exercise your rights:

Email: support@spinsroyaler.com
Address: SpinsRoyaler, Kauppakatu 15, 00100 Helsinki, New Zealand

You also have the right to lodge a complaint with the Finnish Data Protection Ombudsman.