COOKIE POLICY

1. GENERAL PROVISIONS

1.1. Terms and definitions

1.2. Aim of the policy

1.2.1. The Company is committed to ensuring the security of the Website and its Users' personal information and the protection of their rights when visiting the Company's Website and accessing its content.

1.2.2. This Policy has been prepared to provide visitors to the Company's Website with additional information about the technologies used on the Website and how the Company uses them.

1.3. Information about cookies

1.3.1. Cookies are small alphanumeric files that are downloaded and stored on the User's computer or other device (e.g. smartphone, tablet) and saved in the User's web browser during the visit to the website. They may be used to keep track of what pages the User visits on the Website, to store information entered by the User or to remember the User's preferences, such as language settings, when browsing the Website. Cookies also collect information about the number of page views, the duration and the most viewed sections of the Website.

1.3.2. Cookies make it easier to use the Website, and it is possible to disable the collection of cookies by your browser, but this is not recommended as it may reduce the usability of the Website.

1.4. Purpose and legal basis for cookies

1.4.1. Cookies are necessary to enable the User to use the Company's digital services more conveniently, for example, to make online payments, to enable the Company to obtain information about how visitors use the Company's Website, and to enable the Company to improve the services offered to visitors. The Company uses cookies for the following purposes:

1.4.1.1. to be able to provide the Company's services to Website Users;

1.4.1.2. for the Website to function easily and safely;

1.4.1.3. to compile visit statistics.

1.4.2. The Company uses different types of cookies that are placed by default (e.g. "necessary" cookies), but for certain cookies that are used for analytical and targeting purposes, the Company requires the User's consent. By providing consent in the cookie bar that appears when the User visits the Website, the User chooses whether they allow the use of certain categories of cookies. If the User accepts cookies when visiting the Website, the legal basis for the use of cookies is the User's consent, within the framework of which the User confirms that they have read the information about cookies, their purposes and cases of use.

1.4.3. The Website stores information about:

1.4.3.1. Access data (e.g. IP address of the device from which access is made, time of access);

1.4.3.2. The type of web browser used;

1.4.3.3. Demographics (User's age);

1.4.3.4. Website traffic (e.g. which sections were visited, in what services, games the User has shown interest).

1.4.4. Cookies are used for analytical purposes and not to identify someone personally. Cookie files are used to provide the web service offered, if the User does not consent to the use of these cookie files, access to the website services may be difficult and the User may not receive certain services, such as making online payments in the system.

2. TYPES OF COOKIES AND THEIR USE

2.1. The Company uses three categories of cookies, but only two of them require the consent of Users. The User can consent to all categories of cookies or only to one of them. By consenting to a category of cookies, the User consents to all cookies in that category (see detailed list of cookies below). You can change your preferences and refuse cookies at any time.

2.2. When you visit the Company's Website, you may receive long-term cookies, which remain in effect and are not deleted after your visit to the Website ends, or short-term (session) cookies, which expire or are deleted after your visit to the Website ends. All cookies created by the Company can also be divided into the following groups:

2.2.1. Required cookies - which are necessary for the operation of the Company's Website; without such cookies, the interaction between the User's device and the Website could not take place (i.e. the web browser could not access the content of the Company's Website), resulting in the legal basis for processing the data being the performance of contractual obligations with the User and the pursuit of our legitimate interests, such as preserving evidence in the event of the spread of malware, etc.;

2.2.2. Functional cookies - which can only be placed on the user's device after the user's consent has been obtained. The User can express their consent by clicking the "Accept All" button in the pop-up window of the cookie notification. Or they can select specific cookies and click the "Customize" button.

2.2.3. Analytical cookies - inform the Company whether the User has visited our Website before. Such analytical cookies help the Company to keep track of the number of Users and the frequency of their visits.

3. LIST OF COOKIES USED ON THE WEBSITE

3.1. Required cookies - Cookies are essential for the basic functions of the Website and without them the Website will not function as intended. These cookies do not store any personally identifiable data.

3.2. Functional cookies - Functional cookies help to perform certain functions, such as sharing website content on social media platforms, collecting feedback and other third-party functions.

3.3. Analytical cookies - cookies are used to understand how visitors interact with the website. These cookies help us to obtain information about the number of visitors, bounce rates, traffic sources, etc.

4. INFORMATION ABOUT THE PERSON'S CONSENT TO COOKIES

4.1. When visiting the Website, the User will be presented with a window with a message that the Website uses cookies. If the User clicks on the "Accept all" option, this will mean that the User has accepted all cookies that are present on the Website and the User confirms that they have read the information about cookies, the purposes of their use, the cases in which information is passed on to third parties.

4.2. For "required" cookies, the User's consent is not required as these cookies ensure the complete and uninterrupted display of the Website content to enable the User to log in to the Website and have a relevant digital browsing and online experience.

5. REFUSAL OF COOKIES

5.1. If the User wishes to prevent the use of cookies on their device, the User can manage the cookie preferences by ticking the "Customize/Disable All" box in the list of cookies used on the Website. Please note that such changes/choices may affect the functionality of the Website and may prevent you from receiving personalised offers or advertisements.

6. WITHDRAWAL OF CONSENT

6.1. You can change the cookies you allow us to use or refuse the use of cookies at any time. You can refuse all cookies except "required" cookies.

6.2. If you wish to give your consent or withdraw your consent to the analytical, functional cookies, click on the corresponding button: |Withdraw consent | Give consent |.

6.3. The User may request that the Company delete the data about the User that has been collected and processed by means of cookies by contacting [email protected]. These data will be deleted no later than 30 days after a request to that effect has been sent to the e-mail address indicated above, if it is possible to identify the specific user and the data relating to that user.

7. OTHER PROVISIONS

7.1. The Company shall make the Policy available by posting the Policy on the Company's website: https://spins.lv/.

7.2. If the User has any questions about the processing of personal data, please refer to the Company's Privacy Policy, which can be found in the "Privacy Policy" section of the Company's Website(https://spins.lv/lv/privacy-policy) or contact the Company's Data Protection Officer: [email protected].

7.3. This Policy shall be effective to the extent that it is not inconsistent with the laws in force in the Republic of Latvia and shall enter into force upon their approval and shall remain in effect until new regulations are issued or amended. The Company reserves the right to change this Policy at any time. The Company will inform Users of the changes by posting the new version of the Cookie Policy on the Website together with the dates on which the changes were made.

7.4. The User acknowledges that by continuing to use the Website after changes to the Cookie Policy have been made, the User accepts those changes.

APPROVED: 10 May 2023

Version: 2.0