Spinpolo Privacy Policy

What Personal Data Is Collected

Spinpolo collects personal data that users provide directly, as well as data generated through use of the platform. This includes, but is not limited to:

• Full name, date of birth, and government-issued identification
• Contact details, including email address, phone number, and mailing address
• Financial information, including payment method details and transaction records
• Account credentials and login activity
• Device identifiers, IP addresses, and browsing behaviour on the platform
• Communications sent to the support team

Purpose of Collection

Personal data is collected for the following purposes:

• Verifying user identity and age in compliance with Canadian regulatory requirements
• Processing deposits, withdrawals, and other financial transactions
• Delivering account services and responding to user inquiries
• Meeting anti-money laundering (AML) and responsible gambling obligations
• Improving platform functionality and user experience

Technical and Organizational Protection Measures

Spinpolo applies industry-standard security controls to protect personal data against unauthorized access, loss, or misuse. These measures include:

• SSL/TLS encryption for all data transmitted between users and the platform
• Access controls limiting data visibility to authorized personnel only
• Routine security audits and vulnerability assessments
• Secure storage protocols for both active and archived records

User Rights

In accordance with PIPEDA and applicable provincial privacy legislation, users have the right to:

• Access the personal data held about them
• Correct inaccurate or incomplete information
• Request deletion of their data, subject to legal retention obligations
• Withdraw consent to non-essential data processing at any time

Requests regarding personal data may be submitted through the platform’s designated support channels. Spinpolo will respond to verified requests within the timeframes prescribed by applicable law.

Spinpolo processes personal data only for lawful, transparent, and clearly defined purposes. The following outlines how collected information is used:

Account Services

• Creating, managing, and maintaining user accounts
• Verifying identity and confirming eligibility to participate
• Facilitating deposits, withdrawals, and the resolution of transaction disputes

Service Improvement and Analytics

• Analysing platform performance and user interactions to identify areas for improvement
• Monitoring for technical issues and ensuring platform stability
• Conducting internal research to develop and enhance product offerings

Regulatory Compliance

• Fulfilling obligations under Canadian anti-money laundering laws and responsible gambling regulations
• Retaining records as required by applicable legislation and licensing authorities
• Responding to lawful requests from regulatory bodies or law enforcement agencies

Marketing and Communications

With explicit user consent, personal data may be used to:

• Send promotional communications and updates relevant to the user’s preferences
• Deliver personalized content based on platform activity

Users may withdraw consent to marketing communications at any time by updating their account preferences or contacting the support team.

All data processing activities are conducted on a lawful basis, and Spinpolo does not sell or rent personal information to third parties for their own marketing purposes.

Accessing and Updating Personal Data

Users have the right to access the personal data held by Spinpolo and to request corrections where information is inaccurate or outdated. Access requests may be submitted through the platform’s official support channels. Upon receiving a verified request, Spinpolo will provide the relevant information within the timeframe required by applicable Canadian privacy law.

Correcting Personal Data

If a user believes that their personal data is incorrect, incomplete, or no longer current, they may request a correction. Spinpolo will review and update records accordingly, provided the correction does not conflict with legal retention requirements or verification obligations.

Requesting Deletion of Personal Data

Users may request the deletion of their personal data by contacting the support team. Deletion requests will be processed in accordance with applicable law. Certain categories of data may be retained beyond the deletion request where required by regulatory obligations, fraud prevention duties, or ongoing dispute resolution.

Consent to Security Checks and Payment Processing

By registering and using the Spinpolo platform, users acknowledge and consent to:

• Identity verification and security screening conducted by Spinpolo and its authorized compliance partners
• The processing of payment data by third-party payment service providers, who handle financial transactions on behalf of the platform

These processes are necessary for the secure and lawful operation of account services and financial transactions.

The Spinpolo platform is intended exclusively for individuals who are 19 years of age or older, or the applicable age of majority in the user’s province or territory of residence, in accordance with Canadian law.

Spinpolo does not knowingly collect personal data from minors. However, the platform cannot independently verify the age of users without reviewing valid government-issued identification documents during the account verification process.

If a parent or legal guardian believes that a minor has registered on the platform or submitted personal data without authorization, they may contact the support team to request the review and removal of that data. Upon receiving a verified parental request, Spinpolo will promptly investigate and delete any personal information associated with the minor’s account.

Users are responsible for ensuring that no individual under the legal gambling age gains access to their account or uses the platform in their place.

Spinpolo operates in partnership with service providers and technology vendors located in various countries. As a result, personal data may be transferred to and processed in jurisdictions outside of Canada, including countries where data protection laws may differ from those applicable in Canada.

By registering and using the platform, users consent to the transfer of their personal data to partner organizations operating in other countries, for the purposes described in this Privacy Policy.

Spinpolo takes reasonable steps to ensure that all partners receiving personal data are contractually bound to maintain appropriate confidentiality and data protection standards. Data transfer arrangements are reviewed periodically to confirm that user information continues to receive adequate protection regardless of where it is processed.

Certain provisions of this Privacy Policy may modify, limit, or otherwise affect the scope and legal effect of the terms contained herein. Such provisions will apply to the fullest extent permitted under applicable Canadian law.

This Policy and any associated legal disclaimers become binding on a user at the point of:

• Creating a registered account on the Spinpolo platform
• Providing a signature or electronic acceptance where required
• Actively indicating acceptance by using the platform’s services after being presented with notice of this Policy

Users who do not agree with any provision of this Privacy Policy should discontinue use of the platform and contact the support team to request account closure or data deletion. Continued use of the platform constitutes ongoing acceptance of the terms described in this document.

Cookies are small text files placed on a user’s device when they visit a website. Spinpolo uses cookies and similar tracking technologies to support the proper functioning and continuous improvement of the platform.

Purposes of Cookie Use

• Statistical analysis: Measuring traffic patterns and user interactions to evaluate platform performance
• Behavioural analysis: Identifying how users navigate the platform in order to improve content and layout
• Personalization: Storing user preferences and settings to provide a consistent experience across sessions
• Platform improvement: Detecting technical issues and supporting the development of new features

Cookie Retention

Cookies placed by Spinpolo are retained for a period of up to one year from the date of placement, unless removed earlier by the user.

Managing Cookies

Users may configure their browser settings to refuse or delete cookies at any time. Please note that disabling certain cookies may affect the availability or functionality of some platform features. For detailed guidance on managing cookies, users are encouraged to consult their browser’s help documentation.

By accessing and using the Spinpolo platform, users confirm their full and unconditional acceptance of this Privacy Policy in its entirety.

This document represents the current and prevailing version of Spinpolo’s Privacy Policy. In the event of any conflict or inconsistency between this version and any previous version, the current version shall take precedence.

Spinpolo reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or platform practices. Users will be notified of material changes through the platform or via their registered contact information. Continued use of the platform following such notification constitutes acceptance of the updated Policy.

Spinpolo may disclose personal data to third parties in the following circumstances:

• Legal obligations: Where disclosure is required by applicable Canadian law, court order, or regulatory authority
• Dispute resolution: Where sharing information is necessary to investigate, prevent, or resolve a dispute involving the user or the platform
• Contractual agreements: Where service providers are engaged to deliver functions on behalf of Spinpolo, such as payment processing, identity verification, or customer support

A list of categories of third-party recipients is available within the platform. Where a specific recipient is not individually listed, Spinpolo will inform users of the purpose and general scope of the disclosure at the time it occurs.

By providing personal data to Spinpolo and by using the platform, users consent to the disclosure of their information to third parties in the circumstances described above. All third parties receiving personal data are required to handle it in accordance with applicable privacy standards and the terms of their agreements with Spinpolo.

The Spinpolo platform may contain links to external websites operated by third parties. These websites are independent of Spinpolo and maintain their own privacy policies and data handling practices.

Spinpolo is not responsible for the content, privacy practices, or data collection activities of any external website, regardless of how users arrive at those websites. The presence of a link on the platform does not constitute an endorsement or representation of any kind regarding the third-party site or its practices.

Users are advised to review the privacy policy of any external website before submitting personal data or engaging with its services. Any information provided to a third-party website is governed solely by that website’s own terms and policies.