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Privacy Policy
Version 1.0
Last update: 28/04/2025
This Privacy Policy is issued by Clarity Castle s.r.l. ("Company", "We", "Us", "Our", "Website"), a company registered and established under the laws of Costa Rica, with registration number 3-102-931758, and a registered address at PROVINCIA 01 SAN JOSE, CANTON 15 MONTES DE OCA, SAN PEDRO, LOS YOSES, AVENIDAS OCHO Y DIEZ, CALLE TREINTA Y NUEVE, SEGUNDA OFICINA A MANO DERECHA, LY CENTER.
As the data controller, We are legally obligated under relevant gambling regulations to collect and process Personal Information from Users ("You", "Your", "User"). This processing is essential to allow Users to participate in Games and to provide related Services.
By submitting Your information to Spinvoyage, using the Website You agree to the terms set out in this Privacy Policy. If You do not agree with the terms of this Privacy Policy, You should not use the Website.
By using the Website and submitting Your information to Us, You confirm Your consent to this Privacy Policy. If You do not agree with the terms of this Privacy Policy or do not wish to provide the Personal Information required, You should not use the Website.
Please note that this Privacy Policy constitutes a binding agreement between You and the Company. This Privacy Policy is a part of General Terms and Conditions. You should read and understand both Privacy Policy and General Terms and Conditions.
While we’ll make reasonable efforts to inform you of any significant changes, we recommend that you review this Privacy Policy regularly to stay informed of our current practices regarding the collection, use, and protection of your personal information. Your continued use of the Website and/or its services will constitute your acceptance of the Privacy Policy.
Spinvoyage values your integrity and privacy immensely and is committed to managing all Your personal data in a transparent, fair and lawful manner. This Privacy Policy (together with the General Terms and Conditions) sets out the basis upon which Spinvoyage collects, stores, and uses your personal data when You visit Our website, as well as what Your rights are, and how the law protects those rights according to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
We may occasionally update this Privacy Policy, and while We will strive to inform You of any changes, We are not obligated to inform You of all changes to this Privacy Policy and therefore We encourage You to review this Privacy Policy regularly. Your continued use of the Website and its services signifies Your acceptance of the updated Privacy Policy.
This website is solely intended for persons over the age of 18, and We don’t knowingly collect data relating to persons under such age. If it becomes apparent to Us that We’ve collected personal data relating to persons under the age of 18, due to reasons relating to abuse of Our website, we do Our best to ensure that such data is handled in accordance with applicable law.
The Website may collect Personal Information when communicating with You, when You provide Us with information, visit the Website and perform any activities on the Website. Below You will find details on what Personal Information we may collect, how and when we may collect it.
Information you provide us. It includes any of the information that You provide to Us when filling in the forms on Our Player Account registration pages, as well as any other data that You further submit via the website or email. It includes information You provide when You register to use Our website, subscribe to Our service, make deposits, bets or withdrawals on Our website, participate in chat rooms, accept bonuses or other promotions available on Our website, any due diligence documentation You share with Us, including the source of wealth questionnaire and supporting documentation, and when You report a problem or make a complaint with Us. The information you give us may include Your name, username, address, date of birth, country of residence and nationality, identification number, email address, and phone number, financial and credit card information, personal description, proof of identification, proof of address, proof of funds and photograph.
Technical information. It includes the Internet Protocol (IP) address used to connect Your computer to the Internet, Your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about Your visit, including the full Uniform Resource Locators (URL), Information received from cookies.
Gameplay information. Games You played and duration on each game and page, page interaction information.
Analytics information. In some cases, We may collect information about Your use of the services, such as applications' usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs, as well as for research and analytics purposes about Your use of the services.
Information We receive from other sources. This is information We receive about You if You use any of Our websites or services operated by Company. In the event that You use accounts on multiple sites operated by the Company we may collate information about You generated from each website in one data repository. Such data is important to us for statistical purposes, but also particularly relevant within the context of our Anti-Money Laundering and Responsible Gambling responsibilities as arising out of law.
During the course of delivering services to You, we are also working closely with third-party data processors, joint or/and independent data controllers (including, for example, business partners, sub-contractors in technical, payment and delivery services, as well as for delivery of marketing information (such as CRM Tool Providers, Email Marketing Partners, SMS Providers, Direct Mail Distributors and Outbound Call providers,) advertising networks and affiliate networks, analytics providers, due diligence intelligence companies, search information providers, credit reference agencies). This category includes information We receive from Our Publishers, Advertisers and other Partners that we work with to help Us deliver ads and personalised content to You and recognise You across browsers and devices. This may include pseudonymous advertiser identifiers that some Advertisers or other third-party ad platforms choose to share with Us. Data processors process personal data according to Our written instructions and their activities will be limited to those that are needed from them to assist Us deliver the service to You.
When You register for a Player Account on the Website, We collect Your Personal Information necessary to register for the Player Account and to comply with Our legal obligations:
We may collect Personal Information and documents that You provide to Us when You communicate with Our Support Service or other representatives of Our Team regardless of whether through the Chat on the Website, via E-mail or other means of communication. This may happen in the following cases:
We do not collect your Personal Payment Data, such as your payment card number. You provide Your Personal Payment Information to Our Payment Processor where it will be stored in a PCI-certified environment.
We collect certain Personal Information automatically when You use the Website. This includes:
We may legitimately receive certain Personal Information from online vendors and service providers, such as fraud prevention companies. Furthermore, We may use third party vendors to provide technical support, process online transactions and create game content (such as age verification tools, identity or address verification services, regulators or entities that keep central databases of problem gamblers, providers of PEP and Sanction searches). We may access any information You provide to these vendors, service providers and third-party e-commerce services. Any Personal Information so collected will be used and protected in accordance with this Privacy Policy.
We may also receive information about You collected from the other Websites operated by the Company which helps us deliver a better service to You or to keep bonus abusers away, problem gamblers from our services.
We may use the information collected and retained as described above for the purposes described below:
Service Delivery:
We use the Personal Information You provide to fulfill Our contractual obligations, such as creating and managing Your Player Account, providing the Game Services You request, processing Your deposits and withdrawals, and implementing fraud prevention measures. This also includes addressing any inquiries or complaints You may have and managing other essential aspects of Our Services.
Communication:
We may use Your Personal Information to communicate with You, including responding to Your questions and keeping You informed about important updates, such as changes to Our services or policies.
Marketing and Promotions:
With Your consent, We may send You promotional communications about Our products, Services, or special offers that may interest You. These may include information about related products or services from Our Сompany or its associated brands, bonus schemes and promotions and information about the products and promotions, present or future, offered by the brand you registered or with marketing information about brand partners in case you have expressed your consent to receive such materials. You can opt-out of these communications at any time. With Your consent We also may provide customised advertising on the Website based on Your interactions with the Website or Your usage data.
Personalization:
Your Personal Information may be used to personalize Your experience on the Website, including providing You with relevant content and tailored advertising based on Your interactions with the Website.
Website Administration and Internal Operations:
We use Your Personal Information to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes. This Personal Information is typically collected through the use of Cookies.
Legal Compliance:
We process Your information to comply with Our legal obligations, including requirements under Anti-Money Laundering laws and other applicable regulations.
AML, Fraud and Risk Management:
We carry out fraud and risk management activities, including assigning a risk profile or risk status to Your Player Account, to ensure the security and integrity of Our Services.
We process Your information to assess your behaviour and patterns through the Website which will be used to help build a detailed customer profile on You, on different subject matters, including but not limited to:
Please note that for these purposes we partially use profiling with the end decision performed by humans. However, logic behind the profiling and information about it cannot be revealed since it would enable customers to bypass these control mechanisms aimed at the protection of Our business and compliance with legal obligations.
We also may collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from Your personal data but isn’t considered personal data in law as this data doesn’t directly or indirectly reveal Your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if We combine or connect aggregated data with Your personal data so that it can directly or indirectly identify You, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We’ve set out below, in a table format, a description of all the ways we plan to use Your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. In regards to processing personal data based on a legal obligation, we refer to the provisions of the Anti-Money Laundering Directive (EU) 2015/849 of the European Parliament.
Data collected | How do we collect your data? | Purpose for collection | Legal basis for processing data |
---|---|---|---|
Identification data: this includes full name, email, username of choice, date of birth, gender | Requested upon registration |
\ (1) Customer identification and creation of unique customer profile
\ (2) Customer verification for Anti-Money Laundering (AML) purposes
\ (3) Identification of customer when contact is made\ |
\ (1) Performance of contract
\ (2) Legal obligation
\ (3) Performance of contract\ |
Contact details: this includes email address, home address, mobile phone number, skype or any other available mean of communication | Requested upon registration and/or KYC procedure |
\ (1) Customer identification and creation of unique customer profile
\ (2) Contacting customers for support purposes
\ (3) Dissemination of marketing material of the brand
\ (4) Dissemination of marketing material of other Company brands
\ (5) Verification of player identity\ |
\ (1) Performance of contract
\ (2) Performance of contract
\ (3) Consent
\ (4) Consent
\ (5) Legal obligation\ |
Data required for verification purposes: this includes your identification documents, proof of address, and possibly source of funds, source of wealth | Must be uploaded on player profile upon request; may be requested either through pop up on website or via email. |
\ (1) Verification of player identity
\ (2) Required in order for us to comply with AML law\ |
\ (1) Legal obligation
\ (2) Legal obligation\ |
Financial data: this would include the financial details relating to your deposit and withdrawal methods of your choice, therefore your bank details, payment card details, or all relevant details relating to the chosen payment methods | Collected upon deposit or withdrawal of funds into the player account. Could also be collected where we have queries via email / chat / calls |
\ (1) Required to provide you with the service (i.e. to deposit funds into player account)
\ (2) Required for Know-Your-Customer (KYC) checks (source of funds)
\ (3) Required for cybercrime checks
\ (4) To ensure a closed-loop policy\ |
\ (1) Performance of contract
\ (2) Legal obligation
\ (3) Legitimate interest
\ (4) Legal obligation\ |
Transaction data: this includes details relating to payments made to and by you | Automatically generated when deposits and withdrawals are made |
\ (1) Required to provide you with the service
\ (2) Required to comply with AML law and gaming licence requirements
\ (3) Required to track your activity for social responsibility measures\ |
\ (1) Performance of contract
\ (2) Legal obligation
\ (3) Legal obligation\ |
Gaming data: this includes details relating to the games you play on our website (i.e. your gaming activity) | Automatically generated with gaming activity |
\ (1) Required to provide you with the service
\ (2) Required to comply with remote gaming law\ |
\ (1) Performance of contract
\ (2) Legal obligation\ |
Data relating to your communications with us (via email, chat, phone call) | Email correspondence and live chat when contact is made, phone calls may be recorded for record-keeping requirements |
\ (1) Required to provide you with the service (for customer queries, communicating necessary issues)
\ (2) May be used to manage risks, obtain professional advice, or to establish and defend our legal claims, whether in court or in an out-of-court procedure\ |
\ (1) Performance of contract
\ (2) Legitimate interest\ |
Profile data: data relating to your gaming habits and your preferences | Automatically generated with game play, or using cookies to log preferences |
\ (1) May be used in aggregated and anonymised form to improve service
\ (2) May be used for a more personalised user experience
\ (3) Segmentation for AML and social responsibility measures
\ (4) Targeted marketing\ |
\ (1) Legitimate interest. Data in anonymised form is not personal data after that
\ (2) Consent
\ (3) Legal obligation
\ (4) Consent\ |
Responsible gaming data | Self-assessment test |
\ (1) Responsible gaming profiling
\ (2) Identification and investigation of gaming activity for responsible gaming purposes\ |
\ (1) Legal obligation
\ (2) Legitimate interest\ |
Technical data: this may include your Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform Usage data: includes data relating to how you use our website Cookie data |
\ (1) Location data / IP used to ensure customer isn't from a restricted or high-risk country
\ (2) Location data / IP address also used to ensure that they do not use proxies or VPNs, to ensure that they don’t abuse bonuses or defraud by application fraud
\ (3) All other data (including location and IP) is used to improve website functionality, troubleshoot technical issues, create more products for different platforms\ |
\ (1) Legal Obligation
\ (2) Legitimate interest
\ (3) Legitimate interest\ |
|
My RTP data: May include your hit rate, total number of spins, overall RTP on your account, your own RTP compared to the games’ RTPs, biggest win on specific games and bet placed to achieve that win | Automatically generated with gameplay | (1) To ensure we are in line with all the relevant requirements regarding the RTP of our services | (1) Legal Obligation |
We may share Your Personal Information with third parties under certain circumstances to provide Our Services, ensure legal compliance, and enhance Your experience.
Service Providers and Partners:
We work with trusted third-party service providers to perform various functions on Our behalf, such as hosting the Website, processing payments, conducting data analysis, and providing customer support. These service providers will have access to Your Personal Information only to the extent necessary to perform their services and are required to maintain the confidentiality and security of Your Personal Information.
Game providers:
Sometimes our game providers would require access to select data attributes (such as username and IP address, for instance), in order to provide Us with the games You play on Our Website. To check their privacy notice, please visit the relevant website of Game provider.
Payment Providers:
Payments providers (such as GigaDat) and related service providers. Similarly, We may share some of Your personal data with the payment providers You use to make and receive payments on Our Website. To check their privacy notice, please visit the relevant website of Payment provider you’ve used.
Group Affiliates and Employees:
Your Personal Information may be shared with other entities within Our group of companies, including subsidiaries. This sharing is done in a controlled manner to prevent fraud, ensure compliance with legal obligations like Anti-Money Laundering, and promote Responsible Gaming. Certain employees, such as Our Data Protection Officer, Money Laundering Officer, fraud analysts, customer support agents, and others, may access Your Personal Information to perform their duties. All employees with such access are bound by confidentiality agreements (NDA) to respect the confidential nature of the player’s information.
Marketing and Advertising:
With Your consent, We may share Your contact details with marketing partners to send You promotional communications, including emails, SMS, direct calls or direct mail about Our products and services. We may also use third-party advertising companies to serve ads based on Your visits to the Website. These companies may collect data using Cookies and other tracking technologies to provide ads tailored to Your interests.
Legal Compliance and Governmental Requests:
We may disclose Your Personal Information to comply with applicable laws, regulations, or legal processes, such as responding to subpoenas, warrants, or other legal requests. If necessary, We may also provide Your Personal Information to law enforcement agencies, regulatory bodies, or other public authorities. We will take reasonable measures to limit such disclosures to what is strictly required. We may dispute such demands when we believe that the requests are disproportionate, vague or lack proper authority, but we do not promise to challenge every demand.
Client Communication Software:
We use a third-party software to help us communicate with You. This software enables Us to send You emails and chat with You on live chat whenever you have queries.
AML, Fraud and Risk Management:
To protect the integrity of Our Services, We may share Your Personal Information with third-party tools and service providers that assist Us in performing fraud and risk management activities (such as SumSub). This includes assigning a risk profile or status to Your Player Account to prevent fraudulent activities.
Business Transfers:
In the event of a merger, acquisition, or sale of all or part of Our business, Your Personal Information may be transferred to the acquiring entity. We will take appropriate steps to ensure the confidentiality of Your Personal Information during such transactions and will notify You of any changes in ownership or use of Your Personal Information.
Legal and Professional Advisors:
We may share Your Personal Information with legal, financial, and other professional advisors to manage risks, obtain expert advice, or establish and defend legal claims.
Other Disclosures:
We may share Your Personal Information for any other purpose with Your consent or as otherwise disclosed to You at the time of data collection.
We ensure that any third party with access to Your Personal Information is bound to respect its security and confidentiality, processing it only in accordance with Our instructions and for the purposes specified. We do not allow third-party service providers to use Your Personal Information for their own purposes.
Selected third parties, under a data processing agreement with Us that ensures the safeguard of Your personal information, including with:
We always ensure that any third party having access to your personal data is bound to respect the security of your personal data, and to process it in a lawful manner at all times and in compliance with our Privacy Policy and strict codes of conduct. We don’t allow any third-party service providers to use your personal data for their own purposes. Processing by such third parties (also known as ‘Data Processors’) is solely carried out for specific purposes and in accordance with our instructions as Data Controller and on our behalf, and such third parties may only use your personal data to the extent to which we ourselves are entitled. Furthermore, in all cases, we strive to ensure that we don’t share more data than is necessary to be shared for the service providers to carry out the processing activities in accordance with our instructions.
We operate on a global scale and may share Your Personal Information with carefully selected third parties located within the European Economic Area (EEA). These transfers are conducted to support the purposes outlined in this Privacy Policy, ensuring that Your Personal Information is handled in compliance with applicable privacy standards.
When it becomes necessary to transfer Your Personal Information to trusted third parties outside the European Economic Area (EEA), the European Union (EU) and the European Free Trade Association (EFTA) regions we do so by relying on a variety of legal mechanisms to ensure that such transfers are lawful and Your Personal Information remains protected.
In accordance with the General Data Protection Regulation (GDPR), we are obliged to ensure the protection of your personal data during these transfers.
This transfer may be necessary in order to provide You with our services such as:
a) Processing your bets and payment transactions;
b) Providing You with gaming and other ancillary services that You seek from our Website;
c) Identifying and performing the necessary verification checks.
To guarantee an appropriate level of protection for Your personal data during transfers to third countries, we implement appropriate safeguards such as the European Commission’s standard contractual clauses for data protection. We also take all necessary measures to ensure that Your information and data is treated securely and in accordance with this Privacy Policy and all applicable data protection laws.
By using Our Services and accessing Our Website, You accept possible transfer of Your personal data to third countries and the implementation of these safeguards. If you have any questions or concerns regarding these transfers, please do not hesitate to reach out to Us.
We retain Your Personal Information for the duration necessary to deliver Our Services, comply with legal requirements, and support Our legitimate business needs. After Your Player Account is closed, either by You or by Us, Your Personal Information will be stored for the legally mandated period, especially to comply with Anti-Money Laundering regulations. During this time, Your Personal Information may be used if required by authorities for investigations related to financial records, fraud, or other illegal activities.
In addition to this, We may retain anonymized data for longer periods for research and statistical purposes. This anonymized data helps Us improve Our services and marketing strategies, ensuring that no personal identifiers are involved in these processes.
When determining the appropriate retention period applicable to your data, we take several factors into consideration, such as the purposes for which we collect and process such data, the applicable laws and/or regulatory requirements imposed on us, the nature and sensitivity of the personal data, and the potential risks surrounding the unauthorised use or disclosure of such data.
As stated under our General Terms and Conditions both, You and the Casino can decide to have Your Player Account closed at any time. Following closure of Your Player Account, We’ll retain Your personal data on record for as long as required by law. This data shall only be used should it be required by competent authorities in cases of enquiries regarding financial and fiscal records, fraud, money laundering or investigations into any other illegal activity.
You are to note that due to anti-money laundering regulations in licensed gaming jurisdictions in the European Union, we’re obliged to retain personal data of players submitted during registration and any data passed on during the operative period of a player account for a minimum of 5 years from last player transaction or account closure. Therefore, requests for erasure prior to the lapse of this period can’t be entertained.
We are dedicated to protecting Your Personal Information and ensuring the security of Your Account. To prevent unauthorized access, use, or disclosure, We use SSL encryption, firewalls, and access controls, regularly updating Our security practices to meet industry standards.
Only authorized employees, agents, contractors, and third parties with a legitimate need can access Your Personal Information, all of whom are bound by confidentiality obligations. We also work with trusted payment processing providers to ensure secure transactions.
Your Account is secured by a unique ID and password. It’s Your responsibility to keep Your login credentials confidential and secure Your device. All Personal Information is stored in a secure database, protected by advanced firewall software.
You have specific rights related to your Personal Information, which include:
Please note that these rights are subject to certain limitations under applicable laws. If You wish to exercise any of these rights, feel free to contact Us, and We will address Your request in accordance with legal requirements.
We use Сookies to improve Your experience on the Website. Cookies are small data files that websites place on our device when you visit them. These files store information about your visit, such as Your preferences and actions, and allow Us to recognize You during subsequent visits. Cookies enable Us to offer You a more personalized and efficient experience on the Website.
We use Cookies for various purposes, including:
You have the ability to manage and control the use of Cookies through Your browser settings. This includes the option to accept or reject Cookies, delete any Cookies already stored on your device, or configure Your browser to alert You whenever a Cookie is being sent.
Please be aware that if You choose to disable or block Cookies, certain features of the Website may not work as intended, which could negatively impact Your experience.
For detailed instructions on how to manage Cookies, You can consult Your browser’s help section or visit www.allaboutcookies.org.
Also some browsers provide helpful guides:
Should You have any questions about this Privacy Policy, Your Personal Information, or if You wish to exercise any of Your rights with respect to Your Personal Information, please contact Our friendly Support Team: [email protected]. We are always happy to help.
Please note that in some cases emails may end up in spam or may not reach the addressee at all for technical reasons.
If your request isn’t answered within 10 days we strongly recommend you to contact Us again for clarification using alternative methods of communication.