sphspin Privacy Policy

1. Introduction

sphspin ("we," "us," or "our") is committed to protecting the privacy and personal data of every Filipino player who uses our platform. We understand that trust is the foundation of any good gaming experience, and that means being transparent about how we handle your information.

This Privacy Policy describes the types of personal data we collect, the purposes for which we use it, the parties with whom we may share it, and the rights you have as a data subject under Philippine law. Please read this policy carefully alongside our Terms & Conditions and Responsible Gaming Policy.

By accessing or using the sphspin platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree, please discontinue use of the platform immediately.

2. Personal Data We Collect

sphspin collects personal data through various means, including account registration, platform usage, payment processing, and customer support interactions. The categories of personal data we collect include:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth (for age verification – you must be 21 or older)
• Nationality and country of residence
• Email address and mobile phone number
• Residential address (barangay, city/municipality, province)

2.2 Identity Verification (KYC) Data

• Copies of government-issued Philippine IDs (e.g., PhilSys ID, passport, driver's license, UMID, SSS/GSIS ID)
• Proof of address documents (e.g., utility bills, bank statements)
• Source of funds documentation where required by PAGCOR regulations
• Selfie or liveness check images for identity verification

2.3 Financial Data

• Deposit and withdrawal transaction records
• Payment method details (e.g., GCash mobile number, PayMaya account reference, bank account details for BPI, BDO, Metrobank)
• Transaction history and account balance records

2.4 Gaming Activity Data

• Game session logs, bet history, and win/loss records
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session reminders, self-exclusion status)

2.5 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Pages visited, time spent on platform, and click-stream data
• Login timestamps and session duration

2.6 Communications Data

• Customer support chat logs and email correspondence
• Survey responses and feedback submissions
• Marketing preference settings

3. How We Use Your Personal Data

sphspin uses your personal data for the following purposes:

sphspin does not use your personal data for automated decision-making that produces significant legal effects without human review, except where required by law or PAGCOR regulation.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, sphspin processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the sphspin Terms & Conditions, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with PAGCOR regulations, Anti-Money Laundering Act (AMLA) requirements, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where our interests do not override your fundamental rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed consent. You may withdraw consent at any time.

5. Data Sharing & Disclosure

sphspin does not sell your personal data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis:

5.1 Regulatory Authorities

We are required by law to share certain player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies upon lawful request or as mandated by regulation.

5.2 Payment Service Providers

We share necessary financial and identity data with payment processors (including GCash, PayMaya, and partner banks such as BPI, BDO, and Metrobank) to facilitate deposits and withdrawals. These providers are bound by their own privacy policies and applicable Philippine financial regulations.

5.3 KYC and Identity Verification Providers

We may engage licensed third-party KYC service providers to assist with identity verification. These providers process your data solely for verification purposes and are contractually bound to maintain confidentiality.

5.4 Technology and Platform Providers

We work with game software providers, cloud hosting services, and cybersecurity vendors who may process your data as part of delivering the sphspin platform. All such providers are subject to data processing agreements that require them to protect your data in accordance with Philippine law.

5.5 Law Enforcement

We may disclose personal data to law enforcement agencies where required by a valid court order, subpoena, or other lawful legal process under Philippine law.

6. Cookies & Tracking Technologies

sphspin uses cookies and similar tracking technologies to operate and improve the platform. The types of cookies we use include:

• Essential cookies: Required for the platform to function, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences, such as language settings and responsible gaming tool configurations.
• Analytics cookies: Help us understand how players use the platform so we can improve the experience. Data collected is aggregated and anonymized where possible.
• Marketing cookies: Used to deliver relevant promotions and offers. These are only set with your explicit consent.

You can manage your cookie preferences through your browser settings. Note that disabling essential cookies may affect the functionality of the sphspin platform. For more information on managing cookies in popular Philippine browsers and devices, refer to your browser's help documentation.

7. Data Retention

sphspin retains your personal data for as long as necessary to fulfill the purposes outlined in this policy, subject to the following retention periods:

• Account data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required by PAGCOR and AMLA regulations.
• KYC and identity verification data: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Financial transaction records: Retained for a minimum of five (5) years in compliance with AMLA and BIR requirements.
• Gaming activity logs: Retained for a minimum of three (3) years for responsible gaming monitoring and dispute resolution purposes.
• Customer support communications: Retained for two (2) years from the date of the last interaction.
• Marketing data: Retained until you withdraw consent or request deletion, subject to legal retention requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC guidelines.

8. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by sphspin:

To exercise any of these rights, please contact the sphspin Data Protection Officer (DPO) at the contact details provided in Section 13. We will respond to all verified data subject requests within fifteen (15) business days, as required by the Data Privacy Act.

Please note that certain rights may be limited where processing is required for compliance with legal obligations, PAGCOR regulatory requirements, or the prevention of fraud and money laundering.

If you believe your data privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

9. Data Security

sphspin implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and the sphspin platform is encrypted using TLS (Transport Layer Security) protocols. Sensitive data at rest is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorized sphspin personnel on a strict need-to-know basis. All staff with access to personal data undergo regular data privacy training.
• Two-factor authentication: sphspin supports and encourages the use of two-factor authentication (2FA) for all player accounts to prevent unauthorized access.
• Regular security audits: We conduct periodic vulnerability assessments and penetration testing to identify and address potential security weaknesses in our platform.
• Incident response: sphspin maintains a data breach response plan. In the event of a personal data breach that poses a real risk to your rights and freedoms, we will notify the NPC within seventy-two (72) hours and affected players without undue delay, as required by the Data Privacy Act.

While we take all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for keeping your sphspin login credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

10. Children's Privacy

The sphspin platform is strictly intended for adults aged 21 years and older in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the data, and report the incident to PAGCOR as required. If you believe a minor has registered on sphspin, please contact our support team immediately at the details provided in Section 13.

Parents and guardians are encouraged to use parental control tools and to monitor their children's online activity to prevent underage access to gaming platforms.

11. Third-Party Links

The sphspin platform may contain links to third-party websites or services, such as payment provider portals. This Privacy Policy applies solely to data collected by sphspin. We are not responsible for the privacy practices of third-party websites and encourage you to review their respective privacy policies before providing any personal data.

sphspin does not endorse or make any representations about third-party websites linked from our platform. Accessing third-party sites is at your own risk.

12. Changes to This Privacy Policy

sphspin reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. The revised policy will be posted on this page with an updated effective date.

For material changes that significantly affect how we process your personal data, we will notify registered players via email or in-platform notification at least seven (7) days before the changes take effect. Your continued use of the sphspin platform after the effective date of any revision constitutes your acceptance of the updated Privacy Policy.

We encourage you to review this page periodically to stay informed about how sphspin protects your privacy.

13. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact the sphspin Data Protection Officer (DPO):

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.