Privacy Policy
At Spinago, protecting your personal information is a core responsibility. This Privacy Policy explains what data we collect, why we collect it, how it is used, and the rights you hold as a user. By accessing or using Spinago, you acknowledge that you have read and understood this document.
This policy applies to all users located in Australia and is consistent with the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
1. Information We Collect
We collect personal information necessary to operate our services and comply with regulatory obligations. The categories of data we gather include:
1.1 Information You Provide Directly
- Full name and date of birth
- Email address and contact number
- Residential address
- Government-issued identification documents (for identity verification)
- Financial details, including payment method information
1.2 Information Collected Automatically
- IP address and geographic location
- Browser type and operating system
- Session data, including pages visited and time spent
- Device identifiers and cookie data
1.3 Information from Third Parties
In certain cases, we receive data from third-party service providers, including payment processors, identity verification agencies, and fraud detection services. This information supplements what you provide directly and is used solely for the purposes described in this policy.
2. How We Use Your Information
The data we collect serves specific, lawful purposes. We do not sell personal information to third parties under any circumstances.
Your information is used to:
- Verify your identity and confirm your eligibility to use our services
- Process deposits, withdrawals, and other financial transactions
- Comply with anti-money laundering (AML) and responsible gambling obligations
- Detect and prevent fraudulent activity and unauthorised account access
- Respond to customer support queries and resolve disputes
- Send transactional notifications and, where you have consented, promotional communications
- Improve the functionality and security of our services
3. Legal Basis for Processing
We process your personal information on the following legal grounds:
- Contractual necessity — processing is required to fulfil the services you have requested
- Legal obligation — we are required to retain and process certain data under Australian law
- Legitimate interests — fraud prevention, security monitoring, and service improvement
- Consent — for optional communications such as marketing emails, which you may withdraw at any time
4. Data Sharing and Disclosure
Spinago shares personal data only where necessary and under strict conditions. Recipients may include:
- Regulatory and law enforcement authorities, when required by law
- Payment service providers and banking partners processing your transactions
- Identity verification and KYC compliance partners
- IT infrastructure and cloud hosting providers operating under binding data protection agreements
All third parties who receive your data are contractually obligated to protect it and use it only for the purposes specified.
5. Data Retention
We retain personal information for as long as your account remains active and for a minimum of seven years following account closure, in accordance with Australian financial and anti-money laundering regulations. Certain records may be retained longer if required by applicable law or ongoing regulatory inquiries.
6. Your Privacy Rights
As a user based in Australia, you have the right to:
- Access — request a copy of the personal data we hold about you
- Correction — request that inaccurate or outdated information be corrected
- Deletion — request erasure of your data, subject to legal retention requirements
- Objection — object to certain types of processing, including direct marketing
- Withdrawal of consent — opt out of marketing communications at any time
To exercise any of these rights, contact our privacy team through the support channels available on the Spinago website.
7. Cookies and Tracking Technologies
Spinago uses cookies and similar technologies to maintain session integrity, remember user preferences, and analyse site performance. You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of our services.
8. Security Measures
We apply industry-standard technical and organisational safeguards to protect your personal information, including SSL encryption, access controls, and regular security audits. No method of transmission over the internet is entirely without risk; however, we take all reasonable steps to ensure your data remains secure.
9. Changes to This Policy
Spinago may update this Privacy Policy from time to time to reflect changes in law or our practices. The effective date at the top of this document will be updated accordingly. Continued use of our services following any changes constitutes acceptance of the revised policy.
