MySpin Privacy Policy – Protection of Our Members' Personal Data

This Privacy Policy ("Policy") describes how MySpin ("we", "Platform") collects, uses, discloses, and protects your personal information when you use the myspin.vu website, the MySpin mobile app, and all related services.

Myspin takes member privacy very seriously. Every decision related to data management is made with the interests and safety of our members as the top priority. We believe that transparency in how we handle personal data is the foundation of the trust you place in us.

This Policy applies to all MySpin platform users, including website visitors, prospective members, and registered members. It covers all interaction channels — website, mobile app, email, live chat, and other communication channels provided by MySpin.

Myspin collects various categories of personal data depending on the level of platform usage and operational requirements. Below is a full description of the types of data we collect:

We only collect data that is genuinely necessary for the stated purposes. MySpin does not collect excessive or irrelevant data beyond what is needed to operate the platform.

Myspin uses the personal data collected for legitimate and necessary purposes in operating the platform. We do not use your data for any purpose beyond those stated below without first obtaining your consent:

• Account Management: Creating, verifying, and maintaining your member account on the myspin platform.
• Transaction Processing: Processing deposits, withdrawals, and any financial transactions related to your account.
• Identity Verification (KYC): Meeting legal compliance requirements related to age verification and member identity.
• Fraud Prevention: Detecting and preventing fraudulent activity, money laundering, and other security threats.
• Service Communications: Sending important notifications related to accounts, transactions, promotions, and policy updates.
• Platform Improvements: Analysing usage patterns to improve the member experience and platform functionality.
• Responsible Gaming: Monitoring gaming patterns to identify members who may require responsible gaming support.
• Customer Support: Providing assistance and resolving queries or complaints submitted to our support team.

Myspin does not sell member personal data to any party. However, in the course of operating the platform, we may need to share certain information with the following parties:

• Payment Service Providers: To securely process deposits and withdrawals. These providers are bound by strict data protection agreements and PCI-DSS security standards.
• Game Software Providers: Limited data required to run games and ensure the integrity of game results.
• Identity Verification Services: Third-party providers that assist with the KYC process and member document verification.
• Statutory Authorities: When required by law, court order, or a regulatory authority with jurisdiction over our operations.
• Analytics Services: Anonymised data used to understand usage patterns and improve the platform — without revealing individual identities.

All third parties that receive myspin member data are bound by confidentiality agreements and are required to comply with data protection standards equal to or higher than those we apply. myspin conducts regular reviews of all third-party partners to ensure ongoing compliance.

The personal data security of our members is myspin's highest priority. We implement multiple layers of technical and organisational protection to ensure your data is always safeguarded against unauthorised access, loss, or misuse:

• Data Encryption in Transit: All communications between your device and myspin servers are secured with 256-bit TLS/SSL encryption.
• Data Encryption at Rest: Sensitive data stored in our databases, including financial details, is encrypted using industry-standard encryption algorithms.
• Two-Factor Authentication (2FA): myspin supports two-factor authentication to provide an additional layer of security for your account.
• 24/7 Security Monitoring: Automated monitoring systems operate around the clock to detect and respond to any security threats.
• Internal Access Controls: Access to member data among our staff is restricted on a need-to-know basis, with full audit logs maintained.
• Regular Security Testing: myspin systems undergo regular penetration testing and security audits conducted by independent experts.

Myspin uses cookies and similar tracking technologies to enhance the user experience on our platform. Cookies are small text files stored on your device when you visit our website.

Types of cookies we use:

• Essential Cookies: Required for core platform functions such as login sessions and security. These cookies cannot be disabled without affecting platform functionality.
• Performance Cookies: Helping us understand how members interact with the platform — which pages are visited most frequently, time spent, and more. This data is used in aggregate and anonymised form.
• Functional Cookies: Storing your preferences such as language, display settings, and location to provide a more personalised experience.
• Analytics Cookies: Used together with analytics tools to measure platform effectiveness and identify improvement opportunities.

You can control and manage cookies through your web browser settings. However, disabling certain cookies may affect the functionality and user experience of the MySpin platform.

Myspin respects and upholds your rights regarding personal data. As a myspin member, you have the following rights, which you may exercise at any time:

To exercise any of the above rights, please contact our data protection team by email at [email protected]. We will respond to your request within 30 working days. In complex cases, this period may be extended with prior notice to you.

Myspin retains your personal data for as long as it is needed for the purposes stated in this Policy, or as required by applicable law. Below are our data retention guidelines:

• Active Account Data: Retained for the duration that your account remains active on MySpin.
• Data After Account Closure: Transaction and financial data is retained for a minimum of 5 years after account closure to meet legal and financial regulatory requirements.
• KYC Documents: Retained for 5 years from the date of verification or account closure, whichever is later.
• Communication Logs: Customer support logs and communications are retained for 2 years.
• Technical Data: Access logs and security data are retained for 12 months for forensic purposes if required.

Upon expiry of the applicable retention period, your data will be securely deleted or anonymised so that it can no longer be linked to your identity. myspin uses industry-recognised data deletion methods to ensure deleted data cannot be recovered.

Myspin is a platform dedicated to individuals aged 18 and above. We do not knowingly collect or process personal data from individuals under the age of 18.

If we determine that personal data from a child has been collected without appropriate age verification, we will take immediate steps to:

• Immediately closing the account in question.
• Deleting all personal data collected from the underage user in question.
• Refunding any deposits made, following the necessary investigation.

If you believe that your child or someone under the age of 18 has registered on the MySpin platform, please contact us immediately at [email protected] so that we may take the appropriate action without delay.

Myspin reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, technological requirements, or applicable laws and regulations.

When we make significant changes to this Policy, we will:

• Updating the "Last Updated" date shown at the top of this page.
• Sending notifications to members via their registered email or in-platform notices for significant amendments.
• Displaying a summary of key changes to make your review easier.

Continued use of the myspin platform after any amendments take effect constitutes acceptance of the updated Policy. We therefore encourage you to review this page periodically. If you disagree with any amendment, you have the right to close your account and request deletion of your data.

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please do not hesitate to contact us through the following channels:

• Privacy Email: [email protected] — for all data protection and privacy rights enquiries.
• Support Email: [email protected] — for general assistance and account enquiries.
• Live Chat: Available 24 hours a day, 7 days a week via the myspin platform.

Our data protection team is always ready to assist you. We are committed to responding to all privacy-related enquiries within 5 business days, and will provide an acknowledgement of receipt within 48 hours for every enquiry received.