The following statement sets out Our policy relating to the collection, storage and use of personal information in the course of its business.
In this policy:
(a) “we", “us", “our" or “Casino" means Spinfields Management B.V., registration No. 154315, registered address is at Rool Catooje 88, Willemstad, Curacao, license no. №8048/JAZ2020-040.
We take seriously our obligation to safeguard personal information about our clients.
You should review this page periodically so that you are updated on any changes to the policy.
Types of Personal Information we collect and hold
We collect a variety of personal information in the course of our business.
The types of personal information that we may collect and hold includes, without limitation:
- identification information such as your name, date of birth, residential and postal address, gender, email address, telephone numbers;
- financial information;
- copies of identification documents such as drivers licence, passport, birth certificate and/or utility bills;
- personally submitted preferences;
- recordings of telephone conversations and website and app activity;
- responses to competitions, other promotions and surveys;
- and profession, occupation or job title.
How we collect Personal Information
We will collect personal information only by lawful and fair means.
We collect your personal information directly from you unless it is unreasonable or impracticable to do so. We may collect this information when you:
- register for an account with Us;
- access or use our website or apps;
- use our products and services;
- participate in our competitions, giveaways and other promotions;
- contact us directly via any medium including: SMS, MMS, instant messaging, email, social media platforms, postal mail and telephone;
- provide feedback through our website/app feedback links;
and It may also be necessary to collect your personal information from third parties, including:
- credit reporting agencies, law enforcement agencies and other government entities;
- identify verification providers;
- Personal information may also be collected by cookies when you use our website and apps. See Cookies below for further information.
Why we collect, hold, use and disclose personal information
We collect and hold, use and disclose personal information for purposes including the following:
- to allow you to register as a client of Ours;
- to provide products and services to you;
- for communicating with you, including sending you information about our products and services;
- for planning, research, promotion and marketing of our goods and services, including conducting competitions or promotions;
- to create aggregate data about clients through demographic profiling and statistical analysis of our database to optimise our products and services and /or allow for more efficient operation of our business;
- to maintain a credit information file on you and to carry out a credit assessment on you;
- to establish your bona fides;
- for the investigation of suspected unlawful, fraudulent or other improper activity connected with the use of our products and services;
- and to comply with our legal and statutory obligations, including our obligations relating to identity verification and reporting under the Anti-Money Laundering and Counter Terrorism legislation and other applicable laws.
To whom Personal Information is disclosed
By registering with Us and providing personal information you consent to your personal information being used by us and other entities in the Our group of companies.
We share personal information with other entities in Our group of companies in a strictly controlled manner and do not sell personal information to other companies.
We may disclose your personal information to third parties as follows:
- to a credit reporting agency;
- to our contractors and external service providers associated with the operation of our business and provision of our services including, without limitation, associated data centres, web hosting providers, payment service providers, identification verification service providers, advertising agencies, mailing houses, printers, call centres, market research analysts, IT consultants, professional advisors and consultants;
- to law enforcement agencies to assist in the prevention of criminal activities;
- to government and regulatory authorities and other organisations as required or authorised by law or otherwise;
- controlling bodies where such controlling bodies request information to protect and maintain the integrity of services provided or where we consider any betting or gaming activity to be suspicious or unusual;
and to a successor entity in the event of a business transition, such as a merger, corporate reorganisation or to a purchaser of part of or all of Our assets.
Should the information be transferred to a third party, we will use reasonable endeavours to ensure that the information disclosed is protected by the third party under contractual arrangements.
Security of Personal Information
We will take reasonable steps to protect the personal information we collect and ensure that it is accurate, complete and up-to-date.
Your information is held on secure servers. We may also store personal information in telephone recordings and in hard copy or paper files.
Our employees, agents, contractors are required to maintain the confidentiality of all personal information.
You are responsible for ensuring that you keep your username, password and account information confidential. If you suspect that your details may no longer be confidential, you should notify Us immediately, whereupon new details may be given.
You are responsible for the security of and access to your own computer/device. You should ensure that you always log out of your account after each use of the website/app.
Access to and correcting Personal Information
We take reasonable steps to ensure that the personal information we collect about you is accurate, up-to-date and complete. We also take reasonable steps to ensure that the personal information we use or disclose is accurate up-to-date, complete and relevant.
If we are satisfied that your personal information should be corrected we will take reasonable steps to correct it – this may include contacting you to seek your most current information.
You may request access to and correction of the personal information we hold about you. We will require you to verify your identity and to specify what information you require.
You may also update or correct some of your personal information via the “My Account" section of the website/apps.
Overseas transfer of personal information
There may be instances where we may be required to send your personal information overseas or collect personal information from overseas, including:
- where you have asked us to do so;
- when we have outsourced a business activity or function to an overseas provider with whom we have a contractual arrangement;
- or where we are required or authorised by law to do so.
We may disclose your personal information to entities located outside your country of residence, including the following:
- companies in the Our group of companies;
- and external service providers located.
Unsolicited personal information
Where we receive unsolicited personal information, we will determine whether or not it would have been permissible to collect that personal information if it had been solicited. If we determine that collection would not have been permissible, to the extent permitted by law, we will destroy or de-identify that personal information as soon as practicable.
Like most websites and apps, we may collect non-personal information from your use of our websites and apps in order to assist with the administration of our websites and apps, to track site usage and to enhance your user experience.
Once logged in your IP address is tracked against your user ID for the purposes of preventing fraud, identifying improper activity connected with the use of our products and services, and creating an audit trail. We collect and store non-personal information that we collect through cookies, log files or web beacons to create a profile of our users. A profile is stored information that we keep on individual users that detail their viewing preferences. This profile is used to tailor a user’s visit to the Oursite and apps, and to direct pertinent marketing promotions to users.
Cookies are small pieces of data which are stored by a website through your browser, to enable an improved experience whilst using or browsing a particular website/app or to remember your preferences or navigation history/activity (such as pages you have visited within a particular site or typical activity) at a particular site.
We will not use these cookies to store information such as account details or transaction history.
You can delete cookies using your browsers own Clear History function. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website and app features or services may not function properly without cookies.
Most web browsers allow some control of cookies through the browser settings. It is important to note however that if you block cookies from Our site or apps there are a number of functions that may not work and you will need to reset your preferences each time you log in.
Third Party cookies
We may use third-parties to serve ads on our website/apps. These companies may place or recognise cookies, action tags and other technology to measure advertising effectiveness.
To specifically opt-out of interest based ad targeting click here and follow the instructions.
Find out more about cookies
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
If you have a complaint relating to how we handle personal information, please contact our support at firstname.lastname@example.org.