Privacy & Management of Personal Data

Privacy & Management of Personal Data

Last updated: 13 December 2022

All capitalized terms not otherwise defined in this document shall have the meanings ascribed to them in the Terms of Service.

1. General Information

1.1. Fairspin, acting as the data controller, values your integrity and privacy immensely. We only gather information which is really necessary for our operation and we protect it with state of the art security.

1.2. When You choose to open a Member Account You will be asked to provide Us with certain personal information. This information may include Your full name, e-mail address, a chosen password, username, age, valid mobile phone number.

1.3. Fairspin may at its sole discretion request You to provide additional information (e.g. residence address, country of residence) and/or documents (s.a. ID, passport, driver's license). This is important for the ‘Know Your Client’ process as imposed by the anti-money laundering regulations.

1.4. Fairspin will use Your personal data and information to give You access to the Games, for monetary transactions to Your Member Account and to provide You with promotional and operational information for Our services.

1.5. When executing payments in fiat currency, You will need to provide personal payment details such as a credit card number. These details may be stored in the PCI-certified environment of our payment provider and will never be available to the Fairspin staff. Your personal details such as name and address may also be provided to the payment provider. For both Your security and Ours, You may be asked to validate your registered mobile phone number upon a credit card deposit.

1.6. Once a Member Account is opened, Your personal data may be processed for anti-money laundering purposes. We will not take any automated decisions based on Your personal data.

1.7. This Privacy Policy constitutes the integral part of T&Cs. All terms used in this Privacy Policy shall be understood and interpreted as set out in the T&Cs.

2. Data Protection Laws and Regulations

2.1. For the purposes of applicable data protection legislation, the User hereby consents to the processing of any and all personal data (in manual, electronic or any other form) in connection with the User's transactions in relation to Fairspin. You approve and agree that Fairspin may use Your personal details for marketing purposes. We process personal data on the basis of our legitimate business interests and for the performance of the contract with You.

2.2. Fairspin processes personal information collected via its Websites for the purposes of:

  • Setting up and managing Your Member Account;
  • Building up Your personal profiles;
  • Providing you with information about Fairspin promotional offers; and
  • Complying with all regulatory requirements, in particular those relating to the identification of individuals under money laundering legislation.

2.3. You may object to the processing of Your data, insofar as the Agreement can still be performed.

2.4. Access to personal information is limited to the staff of Fairspin and/or its agents in accordance with their roles and responsibilities in managing the above uses in accordance with the applicable Data Protection Act.

3. Confidentiality of Information

3.1. Fairspin shall ensure the confidentiality of the information it has collected about individual Users and will not knowingly allow access to this information to anyone outside of Fairspin, other than to the User himself or as described in this Privacy Policy.

3.2. Being a User, You should ensure that Your Member Account password remains confidential and we recommend that You take appropriate steps to ensure others are not able to access Your Member Account and other information.

4. Confidentiality Limits

4.1. Legally Required Disclosures. Due to the existing legal, regulatory and security environment, Fairspin may be required, under certain circumstances, to disclose personally identifiable information about Our Users. Fairspin will use its best reasonable efforts to limit such disclosure to the following: where Fairspin believes in good faith that it is required to do so in response to a subpoena, warrant or other legal process; or where reasonably necessary to identify, contact or bring legal action against persons or entities to preserve and/or enforce the Fairspin's rights. Further, We can, and You authorize Us to, disclose Your User identification, name, street address, city, state, zip code, country, phone number, e-mail, etc. to third party agents of Fairspin as We, in Our sole discretion, believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy or other unlawful activity or activity that may expose Us to legal liability.

4.2. Customer service representatives and other representatives of Fairspin may have access to the above-mentioned data in order to provide quality customer service and to administer Our business activities.

4.3. We may share Your personal data with any of Farispin’s agents who may only use such data for strictly the same purposes as Fairspin shall specify and within the terms of T&Cs and this Privacy Policy.

5. Global Operations and Data Transfers

5.1. We operate globally and transfer information to trusted third parties within the EEA for the purposes described in this Privacy Policy.

5.2. If we transfer data to trusted third parties outside the EEA, we will rely on multiple legal bases to lawfully transfer personal data around the world.

6. Retention of data

6.1. We keep Your Member Account information, like Your name, email address and password, for as long as Your Member Account is in existence because We need it to operate Your Member Account. In some cases, when You give Us information for a particular feature, We delete the data after it is no longer needed for the feature. We also keep information about You and Your use of Our services for as long as necessary for Our legitimate business interests, for legal reasons, and to prevent harm.

7. Cookies

7.1. We may send You a temporary cookie when You visit the Website. A cookie is a text-only string of information that We place in Your computer's cookie file so that We can remember who You are when You revisit our Website. We may use the data that is generated from cookies to compile statistical data on Your use of the Website. By entering and using the Website and Fairspin services You accept cookies from Us. Please contact our support team: [email protected], if You require any further information about the use of cookies.

8. Consent to Privacy Policy

8.1. By opening a Member Account with Fairspin, You agree to the terms of the Privacy Policy. We may occasionally update the Privacy Policy and encourage You to periodically review it. Your continued use of the Website and Fairspin services constitutes Your agreement to the Privacy Policy and any updates.

9. Users’ Requests

9.1. You have the right to request access to, correction, erasure and/or restriction of Your personal data processed by Fairspin. Any such request must be made in writing to Fairspin at the following address: [email protected] and must be signed by Yourself as the data subject to whom the particular data relates. The processing of such requests sometimes attracts the imposition of a nominal fee.

9.2. Any concerns of Our handling of Your data must be addressed directly with our assigned Data Protection Officer (DPO) available by email - [email protected].