Privacy Policy

SPINS respects your right to privacy. We put in place security measures for your personal data and manage your personal data in accordance with applicable data privacy regulations.

1. Controller of personal data

LTD “BALTENT”, registration number 40203068277, legal address Gertrudes street 12-7, LV-1010, Riga, phone number 63798881 (hereinafter - the Organiser)

2. Applicable Law

Personal Data Protection Law, Regulation 2016/679 of the European Parliament and Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (Regulation) and other applicable privacy and data protection laws.

3. What is Privacy Policy?

Privacy Policy is an agreement between Organiser and an individual (hereinafter – User) who uses the Interactive Gambling Service provided by the Organiser.

The Organiser is committed to protect the User's personal data. Privacy Policy allows the User to understand what information is gathered when Organiser’s service is being used, when the User sends his personal data to the Organiser or the Organiser obtains it into his possession in other way, why does the Organiser obtain this information and how it will be used.

Additionally, the Privacy Policy is providing information about how Organiser is obtaining, processing, storing, sharing, deleting and protecting the Users personal data. That way ensuring that, the personal data is processed lawfully, in good faith and to the User in a transparent manner. Privacy Policy is applicable to Users personal data, any physical personal data processing and provided services.

If the Organiser will update this policy, all changes will be published in Organisers website.

To provide User with better and more suitable services, as well as, to provide, maintain, protect and improve existing services, Organiser process obtained data from provided services.

4. For what purposes User`s data is being gathered?

User`s personal data and other information is gathered to:

provide suitable services, overlook transactions and protect the User from illegal or damaging individual direct or indirect, intentional or unintentional activities, when processing information, which is at the disposal of the persons concerned, as well as to prevent fraudulent activities, illegal betting and money laundering;
process any User`s requested informative requests;
fulfill all Organisers requirements in regulatory enactments;
provide User with support services;
offer and provide User with products and services;
inform User of any software or service updates;
process User`s bets and card or online payments;
create and manage User player account;
comply with Organiser’s legal and regulatory requirements;
create User private profiles;
carry out client research, questionnaires and analyses;
provide User with the information about offers, services and products provided by the Organiser, if the User has agreed to receive such.

5. What User data Organiser processes?

To identify individual person, Organiser takes into consideration the following information, but not limited to:

name;
last name;
date of birth;
personal identification number;
credit institution`s account information;
place of residence;
email address;
data of identity documents;
phone number or other essential information about the person (personal information), including information, which collection is intended by regulatory enactments of Republic of Latvia.

This information is stored on the Organiser’s servers that are located in a secure infrastructure.

When the User is interacting with the Organiser’s provided services, Organiser’s servers are holding an unique activity record for User’s safety, which stores certain administrative and data flow information, including:

IP addresses;
access times;
access dates;
websites previously visited;
used language;
used browsers software error report. This information is important to provide quality service.

Private information is not collected without Users’ consent.

User’s data will not be transferred outside the European Union or the European Economic Area, however, in case if such necessity arises, User’s data can only be transferred to countries that provide the same level of data protection of individual person as provided in the European Union.

6. What tools does the Organiser use for collecting and processing data?

The Organiser can automatically collect the above data and receive personal data, which the User indicates by using the services or otherwise communicating and interacting with the website. The Organiser can also receive personal information from other providers. Similarly, the Organiser may work with third-party providers to provide technical support for online transactions and for the successful maintenance of the User’s account. The Organiser has access to information provided by the User to these service providers and third-party e-commerce service providers, in compliance with all Privacy Policies. The Organiser will use and process the personal information that will be obtained as described in the Privacy Policy.

7. What are the basis for processing of the personal data of the User?

User's personal consent - The User himself, as a personal data subject, gives consent to the collection and processing of personal data for specified purposes. Similarly, the User agrees to the processing of data for direct marketing purposes in order to express new and individual offers (this consent, of course, may be withdrawn by the User). User consent is his free will and independent decision that can be made at any time, thus allowing the Organiser to process personal data for specified purposes. User consent is binding if provided directly and unambiguously. The User has the right at any time to withdraw his/her prior consent using the indicated communication channels with the Organiser. The requested changes will take effect within three working days. The withdrawal of consent does not affect the legality of the processing, which is based on consent before the withdrawal.

Provision of services - in order for the Organiser to provide the User with a qualitative opportunity to participate in interactive gambling, the Organiser must collect and process certain personal data collected prior to registering the User profile on the Organiser’s website.

Legitimate Interests - In keeping with the Organiser’s interests, based on the provision of quality services and timely support to the User, the Organiser has the right to process the User’s personal data to the extent that it is objectively necessary and sufficient for the purposes specified in this Privacy Policy. The Organiser’s legitimate interests include the processing of personal data through direct marketing, resulting in the submission of new and/or individual offers for the Organiser’s products and services to the User. Given that the Organiser is part of a group of companies, it has a legitimate interest in processing its User data by sending it to other group companies for internal administrative purposes, including, on group company level, provision with products and services that are up-to-date with the needs.

Similarly, the Organiser uses personal information collected from the User to provide the service, provide customer support, perform the necessary security and identity verifications, process online payments, assist in the participation of third parties' special offers, if the User agrees to it, to ensure compliance with business specifics and other purposes for which the service is to be provided.

By accepting any competition prize or winning, the User agrees that the Organiser may use the User's name for advertising purposes, for no additional reward consideration, except in situations where it is prohibited by law.

Performance of legal obligations - The Organiser has the right to process personal data in order to comply with the requirements of regulatory enactments and to provide answers to legitimate requests of the state and local government.

8. Exceptions to User data disclosure

The Organiser has the right to disclose personal data only in cases stated in regulatory enactments. If, after the Organiser’s inquiry, it is found that the User has been cheating or attempting to defraud the Organiser, in a way, such as, but not limited to, manipulating with games, manipulating with payments, is suspect of fraudulent payments (using third party or stolen credit cards, fraudulent chargebacks of payments, etc.), by making illegal activities (for example, money laundering activities) to the company or one of the parties involved, the Organiser has the right to process User's personal data (including the User's identity) to prevent, detect, investigate, prosecute or execute a criminal offense or criminal punishment; in order to use personal data in administrative or civil proceedings, as well as in the activities of officials of state institutions authorised by law, if it involves the prevention, detection, investigation or prosecution of criminal offenses or the execution of criminal penalties; in order to prevent immediate imminent threat to public safety. For research purposes and the provision of preventive measures for gambling addiction, anonymous data may be transferred to the responsible authorities.

9. What are cookies?

Organiser may use cookies as a means of collecting information from a web server for the above purposes following the User`s use of the website. If the User registers with the Organiser or if the User continues to use the website, the User agrees to Organiser`s use of cookies. Cookies contain information that is transferred to User`s computer hard drive. Cookies help Organiser to improve the website and deliver a better and more personalised service. Some of the cookies Organiser use are essential for the website to operate. If the User wants to delete any cookies that are already stored on his computer or stop the cookies that keep track of User`s browsing patterns on the website, User can do so by deleting existing cookies and/or altering browser's privacy settings to block cookies (the process User follows will differ from browser to browser).

Cookies, which are strictly necessary Cookies which are strictly necessary are essential for the User to navigate the website and to benefit from the services, for example, when accessing parts of the website that are protected by the safety tools, or in order to carry out money transactions. Without these cookies, Organiser cannot ensure effective operation of the website.

If the User wishes to have more information on how to do this, User can visit www.allaboutcookies.org. By deleting Organiser`s cookies or disabling future cookies means that the User may not be able to access certain areas or features of the website.

10. Duration of storage of User data

The Organiser will process the User's personal data as long as at least one of the following conditions exists: a) the User's profile is active; b) the term of storage of personal data is determined or follows from the regulatory enactments of the Republic of Latvia and the European Union; c) to the extent necessary for the realization and protection of the legitimate interests of the Organiser; d) until the User's consent to the processing of personal data has been revoked.

11. Consent of usage of electronic service providers

In order to make it possible to use the services of game play with real money, and in order to participate in gambling, as well as to receive winnings, the User must make a cash deposits into Organiser’s account. In order to ensure the highest quality of services, Organiser use third party services that allows to electronically process, such cash transactions. By agreeing to this Privacy Policy, User expressly agrees that personal information is necessary to perform such transaction processing, even if the mentioned information needs to be sent outside User’s resident country. Organiser does everything possible to ensure that agreements with the payment system providers protect User’s privacy.

12. What are the security conditions?

The Organiser reserves the right to carry out security inspections at any time to confirm or verify the User’s entered data to verify compliance with the use of the services and to verify the fund transactions made by the User. All this is done to prevent and detect potential violations of the terms and to ensure compliance with the law.

By using the Organiser’s services, the User agrees to the Organiser’s use of Terms and Conditions, the User authorises the Organiser to use the User’s personal information and disclose it to third parties, so that the Organiser can confirm the legitimacy of the information indicated by the User through the Organiser’s services, including cases where information is to be transmitted outside the borders of the User’s country.

Safety checks may include, but are not limited to, reports from the payment card issuing authority or in any other way verifying the information provided by the User in any third-party database. In order to facilitate these security checks, the User agrees to provide additional information or documents at the request of the Organiser.

The Organiser ensures, continually reviews and improves protection measures to protect User's personal data from unauthorised access, accidental loss, disclosure or destruction. To provide this, Organiser applies modern technology, technical and organisational requirements, including using firewalls, intrusion detection, and analysis software and data encryption.

The Organiser carefully scrutinises all service providers that process User's Personal Data on behalf of the Organiser, and assess whether the cooperation partners (data controllers) apply appropriate security measures in order to process the User's personal data in accordance with the delegation of the Organiser and the requirements of the regulatory enactments. Co-operation partners are not allowed to process the Organiser’s personal data for their own purposes.

The Organiser does not take any responsibility for any unauthorised access to personal data and/or loss of personal data, if it does not depend on the Organiser, for example, the User himself discloses his personal data to third parties.

In case of compromise of User's personal data, the Organiser will notify the User thereof.

Similarly, the Organiser shall inform the authorities and the individual persons involved, as specified in the applicable laws and/or regulations, of the data/information security incident, without delay, within 72 hours of becoming aware of the breach of the data/information as it is expected in European Union’s law, unless, in accordance with the principle of accountability, the Organiser can demonstrate that a breach of personal data is unlikely to constitute a risk to the rights and freedoms of natural persons.

The Organiser stores all personal information received from the User in a protected database, part of the data encrypted, the connection of which is protected.

The Organiser’s services are not intended for persons under the age of eighteen (18) years. Any person who provides the Organiser with information through any Organisers provided services proves that he has attained at least eighteen (18) years of age. The Organiser’s policy is to conduct security checks to detect attempts by minors to access services. A suspicion of an underage’s participation in gambling is grounds for launching a security check. If the Organiser becomes aware that the minor has attempted or submitted personal information through any Organiser’s provided services, the Organiser does not accept the information provided by him and take the necessary steps to deny access to the products.

13. User personal data sharing

To provide the User with services, the Organiser may share User’s personal data with Organiser Group companies and partners involved in the provision of services;

The Organiser has an obligation to provide information about personal data to law enforcement agencies, the court or other state and local government authorities, if this is stated by regulatory enactments or at the request of the relevant institution.

The Organiser will only provide the User's personal data only if necessary and sufficient in accordance with the requirements of the regulatory enactments and the objective circumstances of the particular situation.

The Organiser reserves the right, if necessary, to transfer the User's personal data to other Organisational Group companies or service providers if it is necessary for the provision of better service and the provision of quality services to the User.

By participating in games offered by NetEnt, the User agrees to NetEnt's Privacy Policy. You can find NetEnt's Privacy Policy here: NetEnt Privacy Policy

14. What are the rights of the User?

Contact the Organiser for a copy of the personal data held by the Organiser.

Correct all personal data held by the Organiser about one`s self,

The User has the right to obtain information about those individual or legal persons who have received information about this User within a certain period of time from the Organiser. The Organiser will not provide the User with information about the state institutions of criminal proceedings, the operative bodies or other institutions for which the law prohibits disclosure of such information.

Request the removal or limitation of the processing of personal data that is no longer required for the purposes for which they were collected and processed (right to be forgotten).

The User has the right to transfer his personal data.

Contact the Organiser or the processing of personal data in the supervisory institution (Data State Inspectorate, www.dvi.gov.lv) for issues related to the processing of personal data.

You can use the email [email protected] to contact the Organiser.

All information security system issues and information/data security issues that are not covered by this Policy should be addressed to a data processor (email: [email protected])

The operator of this website is SIA BALTENT, Latvian company registration number 40203068277, having its registered address at Gertrudes street 12-7 Riga, LV-1010, Latvia. This website is operated by SIA BALTENT under the following licence, issued and regulated by the Lotteries and Gambling Supervision Inspection of Latvia: licence number TI - 21, (issued on 30-06-2022).