We will always try our best to protect your privacy and try and keep things as simple as possible. We will be transparent about what data we collect and why we use it.
As a Malta-based company, our business is governed by European data privacy law, primarily the EU General Data Protection Regulation.
You can use the spinia-casino.org website without being required to give us any personal information, although, as we explain below, we will collect some information from the device you are using. If you contact us, of course, record your contact information and details of your query.
We collect information from the devices you use to access spinia-casino.org. This includes the following: your IP address (a number that identifies a specific device on the internet and is required for your device to communicate with websites), hardware model, operating system and version, software, user agent, device information, preferred language, serial numbers, device motion information, mobile network information and location data.
We collect Web server log files, which may include information such as dates and times of access, the features or pages you view, app or site crashes and other system activity, the third party site or service you were using immediately before you came to our site, and the URL you go to immediately after leaving our site.
Our website may also use Hotjar. This a third party tool that assists us by providing recording services, which record mouse clicks and movements, page scrolling and any text you key into forms on the site. This data helps us to improve our website, find and fix errors and improve site functionality and is also used for statistical reporting about site use and performance.
‘Cookies’ are small text files stored in your web browser that enables us to recognise your computer when you visit our website. Cookies are essential to keep certain parts of our website functioning correctly and securely. We also use them to make things quicker, easier and more personal to you, and to help us understand how our websites are used. They can also be used to present you with more tailored content or advertising.
Most cookies we use are “session cookies,” which are automatically deleted at the end of a browsing session, but we also use “persistent” cookies. These stay on your hard drive and we use it to automatically recognise you as the same visitor when you return to our site or app. The cookie itself contains no personally identifiable information about you but it does pass an ID to our server which allows us to tie the cookie to you so we can update the homepage to let you know what has changed since your last visit.
Strictly Necessary Cookies: Making Our Websites Work
These Cookies are essential so that you can move around our sites and log in to the secure areas. They also enable us to deliver content to you in a way that works for your device.
Without these cookies you would be unable to access your account, so if you opt out of receiving them parts of our site will not work correctly and may not work at all. A few examples of the ways in which we use strictly necessary cookies:
Functionality cookies: Enabling the Features of the website
These Cookies allow our websites to remember choices you have made, such as your region. We also use them to personalise your experience by, for example, showing different content to regular site users and first time visitors, giving you access to information provided by social media websites such as Twitter, or to show you ‘related article’ links relevant to information you’re looking at.
Without these cookies you will still be able to use the site but might experience difficulty in using certain features and you may find that the content you see on the site is not as relevant to you.
A few examples of the ways we use functionality cookies:
Analytical Cookies – Monitoring the performance of our websites:
These Cookies collect information about how people use our websites and how the sites are performing, e.g. how many people visit, which pages are most popular and whether and where people see error messages.
A few examples of the ways in which we use Analytical cookies:
Without these cookies you will still be able to use and enjoy all the online features of our websites
Web Beacons (‘tracking pixels’)
Our websites and some of the emails we send also contain small invisible images known as ‘web beacons’ or ‘tracking pixels’. These are used to count the number of times the page or email has been viewed and help us measure the effectiveness of our marketing. The web beacons are anonymous and do not contain or collect any information that identifies you as an individual.
Targeting Cookies – Marketing & advertising:
These cookies are used to deliver adverts and content that are more relevant to you as well as to limit the number of times you see a particular advertisement and to measure the effectiveness of advertising campaigns. We also use them to test and improve our products and services by, for example, trying out different product experiences with different groups of customers to see which is most popular
Without these cookies: You will be able to use and enjoy all the features of our websites but the adverts you see will not be tailored to your interests
We use the information we hold about you in a range of different ways, which fall into these broad categories:
We’re telling you this because European data protection law gives you rights over your personal data, which differ according to which of these categories it falls into. This section explains more about each category, the rights it gives you, how to exercise them and what that means in practice.
As you would expect, we use your personal information to provide you with our products and services; respond to queries and provide you with the best possible level of customer service. We use technical information about your device, such as operating system, browser version and location to present you with the correct version of our website and keep it functioning securely and correctly.
Like most organisations, to provide our products and services we share your information with external organisations working on our behalf.
Privacy Rights: Can I opt out of having any of my data used in this way?
This category covers everything that is essential for us to provide you with the service(s) you use or sign up for. If you don’t want your data used in this way your option is to not use our website.
Meeting our Obligations: Legal and Regulatory Requirements
spinia-casino.org needs to comply with a range of legal and regulatory requirements, some of which involve the use of personal information and/or set timescales for which we need to keep that information.
We are also subject to the requirements of laws and regulations relating to other aspects of our business, such as complaint handling or advertising and marketing and some of these too involve the use of, or set timescales for holding, your personal information.
This category covers activities we are obliged to do in order to provide our products and services legally, responsibly, and in line with the requirements of our regulators, and ultimately to protect our customers and our business. If you don’t want your data used in this way your option is to not use our website.
There are some things we do to help us operate as a commercial organisation. We have a legitimate interest in carrying out these activities, and where they involve using your personal information, we are careful to carry them out in a way that minimises any impact on your privacy.
In Europe, data protection law gives you the ‘right of objection’ to the activities in this category if your right to privacy outweighs our legitimate business interest in doing them. You always have the option to exercise this right but, as we explain in more detail below, the activities in this category are central to our business, so if you wish to do so it will usually mean you need to stop using our website.
Please read this section carefully and ensure you are happy with it before providing us with your personal information.
We carry out basic analytics to help us understand, how, when, where and why our customers use our services, and how our business is performing. This helps us monitor and plan everything from the effectiveness of our advertising through to ensuring we have enough staff available to handle queries at peak times. It also gives us a much clearer picture of our customers generally, the broad demographic groups they fit into (e.g. age group, gender, location, etc.) and the products and services they use, which in turn helps us to develop better and more relevant features, products and services. We do this analysis in a way that does not identify individual customers so there is no impact on the privacy of any one person.
Privacy Rights: Can I object to this?
Like any business, we need to keep a close eye on how our business is performing and whether we’re meeting the needs of our customers. As we take care to do this in a way that does not identify you as an individual, there is no impact on your privacy. If you don’t want your data used in this way your option is to not use our website.
Whichever products or services you use, wherever and however you interact with us, we want to give you the same great level of service and make it personal to you. We will tailor your experience, personalising the layout and content of our sites according to what we know about you, your preferences and how you like to use our services. For example, we will present you with features we know you have used or think you are likely to use, and personalise search results to show more relevant results first.
We also look at aggregated (non-identifiable) data showing the products and features our customers use and based on that we suggest products and features we think you’ll enjoy because they are popular with other people who use the same products and features as you.
Privacy Rights: Can I object to this?
We believe this personalised experience makes our website and your experience better and we want to give you the best customer experience we can. Using your personal data in this way enables us to do that, and does not have an impact on your privacy. If you don’t want your data used in this way your option is to not use our website.
Please note that some aspects of your customer experience are provided via cookies. If you have enabled cookies in your browser, we will personalise certain aspects of our site, such as remembering your location, and you can control this via your browser settings.
Most people use our products and services fairly, but if we become aware of account activity or behaviour that could be prejudicial to our commercial interests, we will investigate.
Privacy Rights: Can I object to this?
As a business, we have a legitimate interest in protecting our commercial interests against deliberate misuse, and we are confident that we do it in a way that is proportionate to the risks we face and has minimal impact on your privacy. If you don’t want your data used in this way your option is to not use our website.
We will occasionally invite you to give feedback on the services you have used or to take part in customer surveys, questionnaires or focus groups. We will contact you online or via email, directly. Taking part in research is always voluntary, and where we use a third party we do not pass over any details (other than your contact details so they can send you the initial request or invitation) unless and until we have your consent to do so.
Privacy Rights: Can I opt out of this?
It’s really important for any business to find out what its customers think. As we are careful to limit the number and frequency of feedback/research requests we send to any one person, and you can always decline to take part, there is no adverse impact on your privacy and you cannot opt out of receiving these occasional requests.
We will send you offers and information only if you have given your consent for us to do so, in which case we will contact you via email, post, SMS or online. We never share your data with third parties. From time to time, we may team up with a third party to bring you details of a product or service we think may interest you, but where we do this the contact will come from us – we will never pass your details to a third party without your prior consent.
We want to make betting and gaming better for you, so we want to be able to tell you about products, services and features that you will find exciting and relevant and we tailor the offers and information we send to suit you. To do this, we look at what we know about you so we can fine-tune the offers we present to you.
We firmly believe our customers prefer offers and information that are relevant to them and their interests over general adverts, so we tailor all our marketing using this picture we’ve built up of you. We think this makes our marketing better both for you and for us. However, data protection law gives you the right to opt out of having your personal data used to build up this type of picture and predict what you might be interested in, so you can opt out at any time. As we explain above, all our marketing is tailored to you in this way, so to opt out of this type of personalisation you will need to opt-out from any messaging services from spinia-casino.org you have subscribed to, but we will continue to personalise your online experience based on the picture we’ve built up of you. This means you’ll continue to benefit from a more personalised look and feel on our websites and will still see the following:
We think this strikes the best balance: it lets you opt out of receiving marketing through offline channels (post, email and SMS) while still enjoying the best online experience, and without having to miss out on benefits. However, if you prefer not to receive any personalised messages or offers online you can opt out by not using our website.
Please also note the following:
All our marketing is tailored to be more relevant and interesting to you, so if you’re:
Remember, you can change your mind at any time by updating your preferences.
If you have enabled cookies in your browser you may receive banner adverts on our website, as these are cookie-based and not tailored using other information we hold about you. As they are cookie-based you may receive them even if you have opted out of other personalised marketing but you can control them easily via your browser settings
If you have given your consent to marketing, we may work with social media companies such as Facebook and Twitter to provide you with information about our products and services via their platforms. If you do not wish to see these adverts, you can control this easily by disabling preference-based marketing in the privacy settings on each individual platform.
Even if you have withdrawn your consent to personalised marketing by us, you may still occasionally see general adverts for our group products and services on your social media feeds. These will not be specifically targeted to you, and again, you can control this via the privacy settings on each platform.
We share your personal information with external organisations that carry out a range of services on our behalf for the purposes in this policy. The main functions that are, or may be, carried out fully or in part by third parties are listed below:
We carry out checks to ensure that the companies we work with will give your information the same level of care and protection as we do. Both we and they are obliged to handle your information in accordance with data protection law, and we are also required to put in place contractual measures reinforcing those obligations.
Some of the third party providers we use are based in, or carry out some of their activities in countries outside the European Economic Area (EEA), which is made up of the EU Member states plus certain countries considered to offer a standard of data protection equivalent to that of Europe.
Where this means personal information is transferred outside the EEA, we have to put in place additional legal protections on top of our standard checks and measures, to ensure it receives the same level of protection as it would within Europe. We do this by using standardised contractual clauses (sometimes called ‘the EU Model Clauses’) approved by the European Commission and European privacy regulators, although there are alternative approved legal mechanisms which we can decide to use instead. Where necessary, we also put in place any additional contractual measures required by local law in any of the countries in which we operate, except where they conflict with the General European Data Protection Regulation.
Apart from the functions set out above, we do not share your personal information with third parties except where we are compelled or permitted by law to do so. These circumstances are rare, but may require us to share information with the police, courts or other law enforcement agencies, statutory bodies (in relation to matters such as taxation) and sporting bodies (in connection with sporting integrity issues), in any of the countries in which we operate.
Where necessary to protect or defend our rights and interests, resolve disputes or enforce our agreements, we will share personal data with our regulators, external legal advisors and debt recovery and tracing agencies, although again these circumstances are rare.
If ownership of all or part of our business changes or we undergo a reorganisation or restructure, we will transfer your personal information to the new owner or successor company so we or they can continue to provide the services you have requested.
Whenever we share personal information, and whatever the circumstances, we will always do so legally and with due regard to your privacy.
We hold your personal information only as long as we have a valid legal reason to do so, which includes providing you with the services you have requested, meeting our legal and regulatory obligations, resolving disputes and enforcing our agreements.
The length of time for which we keep different types of personal information can vary depending on why we originally obtained them, the reason we process them and the legal requirements that apply to them. When setting our data retention and deletion timescales we take into account a range of factors and requirements including: gambling regulation, anti-money laundering rules, tax rules, payment industry requirements, complaint handling standards, the need to prevent or detect crime or other misuse of our services, and audit requirements.
To fulfil our various requirements and obligations, some of your personal data will need to be retained for a period of time after you cease to be a customer.
When we no longer need your personal information to fulfil the above requirements, we delete it securely. Where we wish to retain any information for analysis purposes, we first anonymise it to the standards approved by the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, AP) so that it can no longer be linked back to an individual. Please note that if you opt out of receiving marketing from us, we will still need to keep your contact details in order to suppress them from future marketing activity.
We respect the fact that your personal information is your information so we want to be clear about what those rights mean in practice and how you can exercise them.
You can opt out of receiving direct marketing at any time. You also have the right to opt out of having your information used to create a picture of you that we use to create a ‘profile’ of you for marketing purposes ‘).
We firmly believe that our customers prefer to receive offers and information that are relevant to them so we tailor all of our marketing to make it more relevant and interesting to our customers. In practice this means that if you wish to opt out of having your information used to personalise your marketing, you will need to opt out of receiving all direct marketing from us.
Data protection law gives you the right to express an ‘objection’ to activities detailed in the section entitled ‘Running our business effectively and efficiently’ if you believe your privacy rights outweigh the legitimate interest we have as a business in doing those things. Please read this section carefully before getting in touch with us and note that exercising your right of objection will usually mean you need to stop using our services. If you disagree with our decision on this, you have the right to complain to the privacy regulator
People sometimes refer to this as the ‘right to be forgotten’. Under data protection law, you have the right to request erasure of your personal data in the following circumstances:
If you would like a copy of the personal information CАЙТ holds about you, you should request it here. We will ask you to complete and return a form, which is not compulsory but helps us to help you by providing the information you are looking for. Before we respond to your request, we will ask you for valid proof of identity and once we’ve received it we will provide our response within one month. If your request is unusually complex and likely to take longer than a month we will let you know as soon as we can and tell you how long we think it will take.
We will fulfil requests wherever possible, but there are occasional situations in which local or European data protection law requires or permits us to withhold some information (such as where it would involve disclosing information about another person or information which is commercially sensitive), or allows us to make a small charge. If either of these applies, we will tell you why.
The right to ‘data portability’ aims to enable consumers to re-use some of their personal information online by making it available in a commonly-used, machine-readable format that can be passed to and used by other organisations. This is a new initiative and it is not yet possible to ‘port’ data directly between providers in the betting and gaming industry. However, if you wish to exercise this right, you should submit your request here, and we will provide you with the following information as a CSV file:
Before responding to your request, we will ask you for valid proof of identity, and we will provide our response within one month of receiving it.
Your right to complain to the regulator
If you believe your privacy rights have been infringed, or you disagree with a decision we have made about your privacy rights, you have the right to complain to the privacy regulator.