33spin Privacy Policy

1 Introduction

33spin is committed to protecting the privacy and security of all players who use our Platform. We understand that your personal data is important to you, and we take our responsibility as a data controller seriously. This Policy applies to all personal data collected by 33spin in connection with your use of the Platform, whether you are a registered player, a visitor to our website, or a person who contacts our support team.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming policy, both of which are incorporated by reference.

2 Data We Collect

33spin collects the following categories of personal data from players and platform users:

33spin does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by applicable law or regulatory obligation (for example, responsible gaming assessments).

3 How We Collect Data

33spin collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Data collected automatically when you access the Platform, including cookies, web beacons, pixel tags, and server logs that record technical and usage data.
• Third-party sources: Data received from payment processors (such as GCash and PayMaya), identity verification providers, fraud prevention services, and analytics partners, where permitted by applicable law.
• Regulatory sources: Data received from gaming regulatory authorities or law enforcement agencies in connection with our legal and compliance obligations.

4 How We Use Your Data

33spin uses your personal data for the following purposes:

• To create, manage, and maintain your 33spin player account.
• To verify your identity and age in compliance with Philippine gaming regulations, including the mandatory 21-years-and-older requirement.
• To process deposits, withdrawals, and other financial transactions via GCash, PayMaya, BPI, BDO, Metrobank, and other accepted payment methods.
• To provide customer support and respond to your enquiries, complaints, and feedback.
• To personalise your experience on the Platform, including game recommendations and promotional offers tailored to your preferences.
• To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct.
• To comply with our legal and regulatory obligations, including anti-money laundering (AML) and know-your-customer (KYC) requirements.
• To monitor and improve the performance, security, and functionality of the Platform.
• To send you service-related communications, including account notifications, security alerts, and policy updates.
• To send you marketing communications about 33spin promotions, bonuses, and new games, where you have provided consent or where we have a legitimate interest to do so.
• To support responsible gaming obligations, including monitoring for signs of problem gambling and facilitating self-exclusion requests.

5 Legal Basis for Processing

33spin processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable regulations:

• Contractual necessity: Processing required to fulfil our obligations under the Terms & Conditions, including account management and payment processing.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML, KYC, and gaming regulatory requirements.
• Legitimate interests: Processing carried out for fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your explicit consent, including the sending of marketing communications. You may withdraw your consent at any time by contacting 33spin support.

6 Data Sharing

33spin does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only where necessary and in accordance with this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your financial transactions.
• Identity verification providers: Third-party KYC and age verification services used to confirm your identity and eligibility to use the Platform.
• Fraud prevention and security services: Providers that assist 33spin in detecting and preventing fraudulent activity and ensuring platform security.
• Analytics providers: Services that help 33spin understand how the Platform is used, in order to improve performance and user experience. Data shared with analytics providers is aggregated and anonymised where possible.
• Regulatory and law enforcement authorities: Gaming regulators, the National Privacy Commission, law enforcement agencies, and other government bodies, where required by applicable law or regulatory obligation.
• Professional advisers: Legal counsel, auditors, and other professional advisers, where necessary for the conduct of 33spin's business.

All third parties with whom 33spin shares personal data are required to handle such data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than that for which it was shared.

7 Cookies & Tracking Technologies

33spin uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that allow us to recognise you and remember your preferences across sessions.

We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly. These cannot be disabled without affecting core functionality, such as maintaining your login session and processing transactions.
• Performance and analytics cookies: Used to collect information about how players use the Platform, such as which pages are visited most frequently. This data is used to improve the Platform's performance and user experience.
• Functionality cookies: Used to remember your preferences and personalise your experience, such as your preferred language or game settings.
• Targeting and marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. These are only placed with your consent.

You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform.

8 Data Retention

33spin retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

In general, 33spin applies the following retention periods:

• Account and identity data is retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and gaming regulatory requirements.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for a period of two (2) years from the date of the interaction.
• Technical and usage data is retained for a period of up to two (2) years, after which it is anonymised or deleted.

Where personal data is no longer required, 33spin will securely delete or anonymise it in accordance with applicable data protection standards.

9 Data Security

33spin implements a comprehensive range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 33spin Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Strict access controls ensuring that only authorised 33spin personnel can access player data, on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform's infrastructure.
• Multi-factor authentication requirements for internal systems that process player data.
• Incident response procedures to detect, report, and address any personal data breaches in a timely manner.

While 33spin takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, 33spin will notify you and the National Privacy Commission in accordance with applicable law.

10 Your Rights

Under the Data Privacy Act of 2012 and applicable regulations, you have the following rights in relation to your personal data held by 33spin:

• Right to be informed: You have the right to be informed about how your personal data is collected and processed, as set out in this Policy.
• Right of access: You have the right to request a copy of the personal data that 33spin holds about you.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data held by 33spin.
• Right to erasure: You have the right to request deletion of your personal data, subject to 33spin's legal and regulatory retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission if you believe that 33spin has not handled your personal data in accordance with applicable law.

To exercise any of these rights, please contact the 33spin support team. We will respond to all valid requests within thirty (30) days. We may need to verify your identity before processing your request.

11 Children's Privacy

The 33spin Platform is strictly intended for adults aged 21 years and older, in accordance with Philippine gaming regulations. 33spin does not knowingly collect personal data from persons under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you believe that a minor has registered an account on the 33spin Platform, please contact our support team immediately so that we can investigate and take appropriate action.

12 Third-Party Links

The 33spin Platform may contain links to third-party websites or services. This Privacy Policy applies solely to the 33spin Platform and does not cover the data practices of any third-party websites. 33spin is not responsible for the privacy practices or content of any third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

13 Policy Updates

33spin reserves the right to update or amend this Privacy Policy at any time. Any changes will be posted on this page with an updated effective date. Where changes are material, 33spin will endeavour to provide reasonable notice to registered players via email or in-platform notification. Your continued use of the Platform following the posting of any updated Policy constitutes your acceptance of the revised terms.

We encourage you to review this Policy periodically to stay informed about how 33spin protects your personal data.

14 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 33spin handles your personal data, please contact our Data Protection Officer or customer support team. We are available 24/7 to assist you.

Email: [email protected]

For information about your rights as a data subject under Philippine law, you may also contact the National Privacy Commission directly. For responsible gaming support, please visit our Responsible Gaming page.