1. GENERAL

As a data controller, we have a legal obligation under gambling regulations to process personal data from players to allow them to participate in games and provide them with ancillary services. This Privacy Policy explains what personal data we collect from players, why we collect it, and how we use it.

If you have any questions regarding this Privacy Policy or the protection of your data, feel free to contact our Data Protection Officer at support@evospin.com.

By registering a Player Account with the Website, 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 us with the required personal information, please do not use this website.

This Privacy Policy constitutes an agreement between you and the Company. We may periodically make modifications to this Policy. While we will do our best to notify you of such changes, we recommend that you revisit this Privacy Policy regularly. Your continued use of the Website and its services will constitute your consent to the updated Privacy Policy.

2. INFORMATION WE COLLECT

The Personal Information we may request to use and process includes, without limitation:

• Information provided when filling in forms on our account registration pages or other data submitted via the Website or email (e.g. first and last name, date of birth, email address, phone number);
• Correspondence made with us via the Website, email, web chat, or other means of communication;
• All Player Account transaction history, whether via the Website(s) or other means of communication;
• Website logins, traffic data, GeoIP location data, browser/device data, activity logs, and other traffic information recorded in our system;
• Documents and proofs reasonably requested to verify your account, process deposits or withdrawals, and conduct anti-fraud checks. Such proofs may include passport scans, payment slips, bank statements, etc.;
• Survey participations or any other customer assessments carried out by us from time to time.

3. HOW WE USE YOUR INFORMATION

We process the Personal Information collected from you in order to deliver our services. In particular, your data is used for the following purposes:

• Processing bets and transactions, including credit card and online payment systems;
• Providing gaming and other ancillary services;
• Rendering customer support, such as assistance with setting up and managing your account;
• Identifying and performing necessary verification checks;
• Providing information about promotional offers, if consented to;
• Complying with legal obligations, including anti-money laundering (AML) and combating financing of terrorism (CFT) laws;
• Monitoring transactions to prevent fraud, money laundering, or other irregular gaming activities;
• Analyzing customer trends and conducting market studies (participation is voluntary);
• Conducting research and statistical analysis of aggregated data.

4. MARKETING COMMUNICATION

Unless you have opted out, we may use your Personal Information, such as your email address or phone number, to send marketing communications about our products, services, and promotions. This may include information from our business partners, such as casino game providers.

If you wish to stop receiving such marketing materials, you can opt-out in your Player Account settings or by contacting customer support at support@evospin.com.

By accepting any contest prize or winnings from us, you consent to the use of your name and/or nickname for advertising and promotional purposes without additional compensation, except where prohibited by law.

5. OBTAINING PERSONAL INFORMATION

We shall not collect any Personal Information about you without your knowledge. We may, however, automatically collect certain data about you where you have provided such information through the use of our services and through your interactions with us.

We may also lawfully receive certain Personal Information from online vendors and service providers, such as fraud prevention companies. Additionally, we retain the right to engage third-party providers to render technical support, process your online transactions, and source gaming content.

Any information you provide to such vendors, service providers, and third-party e-commerce services may be accessed by us. Rest assured that we will use and safeguard any Personal Information obtained in accordance with this Policy. Personal Information will only be disclosed to third parties outside the Company as outlined in this Privacy Policy, and we take necessary steps to ensure agreements with third-party service providers protect your data.

6. DATA RECIPIENTS

We may share the information you provide with entities within our group of companies and our business partners, including parent companies, subsidiaries, and companies with whom we do business. Data processing may be handled by the Company or another entity within our group, potentially using third parties for processing needs.

Access to your Personal Information is granted to Company employees such as Data Protection Officers, Payments & Anti-Fraud analysts, Customer Support agents, and others who require this information to perform their duties. All employees involved with personal data have signed confidentiality agreements to protect the privacy of your information, as required by applicable data protection laws.

Transfers of your data may be necessary to countries outside the European Union (EU), the European Free Trade Association (EFTA), and the European Economic Area (EEA) to provide services. We ensure your data is protected during such transfers, following GDPR regulations and using appropriate safeguards such as standard contractual clauses. By using our services, you accept the transfer of your personal data under these safeguards.

7. RELEASING DATA TO THIRD PARTIES

We do not sell or rent your personal data to third parties. However, we may disclose your personal information if required by law, regulation, or a legal subpoena. Additionally, we may disclose data to protect the legitimate interests of the Company, its customers, or third parties.

Personal data may be disclosed to third parties in the following cases:

• Where required by law;
• If sharing data with payment processors is necessary to facilitate transactions (e.g., most card transactions are processed by Paysafe);
• To comply with legal and regulatory obligations under licensing and regulatory authorities;
• If necessary to protect the safety of the Company, players, or others, or to investigate fraud;
• To marketing service providers for promotional activities;
• With the player's prior consent.

We use third-party data processors for limited purposes, such as website hosting, marketing, analytics, and email newsletters. We ensure these processors comply with data protection laws and impose the same obligations on them as required by our Service Agreements.

Our websites may include social media features like "share" or "like" buttons from platforms such as Facebook. Any data collected this way is processed according to the respective social media platforms' privacy policies.

If the Company undergoes changes like a merger, acquisition, or sale, customer data may be included in the transfer. We will notify players via email before any such transfer occurs.

Please note that our content may link to third-party websites, which have their own privacy policies and data processing disclosures. We are not responsible for these external websites.

8. DATA RETENTION

As stated under our Terms and Conditions, both you and the Casino can decide to have your Player Account closed at any time. Following the closure of your account, we will retain your personal data on record for as long as required by law. This data shall only be used if required by competent authorities in cases of inquiries regarding financial and fiscal records, fraud, money laundering, or investigations into any other illegal activity.

We may also keep anonymized derivatives of your data to improve our content and marketing communications where no automated decision-making is involved.

Due to anti-money laundering regulations in licensed gaming jurisdictions within the European Union, we are obligated to retain the personal data of players submitted during registration and any data passed on during the operative period of a Player Account for a minimum of five years from the last player transaction or account closure. Therefore, requests for erasure prior to the lapse of this period cannot be entertained.

9. SECURITY OF YOUR DATA

We acknowledge that in collecting and processing your Personal Information to manage your Player Account, we are bound by strict legal provisions on data protection. Consequently, we strive to protect your personal information and respect your privacy in accordance with best business practices and applicable regulations.

We are committed to providing secure services to players, and we take all reasonable precautions to ensure that all data you have submitted to us remains safe.

Right to withdraw consent. In cases where we rely on your consent for processing personal data, you have the right to withdraw your consent at any time.

Player Accounts can only be accessed with the player’s unique ID and password. You may also set up two-factor authentication (2FA) for additional protection against unauthorized access. You are responsible for keeping your login information confidential and ensuring it is not accessed by another person.

10. YOUR RIGHTS

Data protection law grants you, as a data subject, certain rights in specific circumstances. In accordance with the law, you have the right to:

• Request access to your personal data – You have the right to request, free of charge, a copy of the personal data we hold about you;
• Request correction of your personal data – If any personal data we hold about you is incomplete or incorrect, you have the right to have it corrected (we may request proof such as ID or proof of address to support your request);
• Request erasure of your personal data – You may request the erasure of your data where there is no legal basis for us to continue processing it. Please note this right is not absolute and may be denied if we are legally obligated to retain the data;
• Object to processing of your personal data where we rely on legitimate interests to process your data, if you believe our processing impacts your fundamental rights and freedoms. However, we may demonstrate compelling legitimate grounds to continue processing your data;
• Request restriction of processing – You can ask us to suspend the processing of your data in the following scenarios: (a) you want us to verify the data’s accuracy, (b) our use of the data is unlawful but you don’t want it deleted, (c) you need the data to establish legal claims, or (d) you objected to our use of the data but we need to verify overriding legitimate grounds;
• Request transfer (data portability) – You may request us to provide you with certain data you initially provided, which we process using automated means, so you can transfer it to another controller;
• Withdraw consent – If we rely on your consent to process your data, you may withdraw it at any time without affecting the lawfulness of prior processing. Withdrawing consent may mean discontinuation of certain services (e.g., marketing communications);
• Lodge a complaint with a supervisory authority.

To exercise your rights, we may request specific information to verify your identity. This security measure ensures we only disclose personal data to the correct person.

11. CONTACTING US

You may always contact us regarding this Policy should you wish to:

• Confirm the accuracy of the personal information we have collected about you;
• Enquire about our use of your personal information;
• Prohibit future use of your data for direct marketing purposes;
• Update or rectify any information you have provided (in such cases, we may require evidence to effect these changes). It is illegal to provide false information.

We have appointed a Data Protection Officer (“DPO”) responsible for overseeing questions related to this Privacy Policy. If you have any questions about this privacy policy, please contact the DPO at support@evospin.com.

Additionally, as per Article 77 of the GDPR, you have the right to lodge a complaint related to your data processing with a supervisory authority, particularly in the Member State of your habitual residence, place of work, or the place of an alleged infringement.

12. COOKIE POLICY

When you visit the Website, our system automatically collects information about your visit, such as your browser, IP address, and the referring website. This collection may be done in conjunction with our platform providers and partners. We may receive from them general demographic or usage data of our Website visitors. We do not use automatically collected information to identify you personally without receiving additional consent.

To collect the information in question, we use cookies and similar tracking tools. Cookies are small text files stored on your computer or equipment when you visit our web pages. Some cookies are essential for the Website's operation; others improve your Website experience and help us deliver better service. Below are the types of cookies we use and their purposes:

• Required cookies: Enable the navigation and basic functionality of the websites, e.g., access to member areas of the Website.
• Functional cookies: Allow us to analyze your website usage and your selections (e.g., session key, language, region) to save these settings and offer a more personalized experience.
• Advertising cookies: Help us gauge the effectiveness of our content marketing. These cookies are provided by our partners to track website visits and new player registrations from advertising. We do not share your personal information (such as name or email) with affiliated partners, except for site visit data collected by Advertising Cookies. However, your site visit data may be linked to other personal information collected through other sources by the providers. This external data processing is governed by the privacy policies of third-party providers.

We also use a number of third-party service providers who may set cookies on this Website. These services help us track your activity on the Website, measure the effectiveness of the Website, and assess our marketing campaigns.

Most online browsers automatically accept cookies. However, you can block or delete cookies by modifying your browser settings. Note that blocking or deleting cookies may restrict your use of our Website.

13. NETENT GAMES

When you play casino games developed by NetEnt, NetEnt’s Privacy Policy also applies. This policy can be found on the NetEnt Terms page.