Privacy Policy

This Privacy Policy covers the processing of the personal data that we collect or disclose when you visit www.spinheroes.info

1. Information concerning the processing of personal data
Your data security is important to us, and consequently, we prioritize handling your data responsibly.

In the following sections, you can read how Spinheroes.info (subsequently “we,” “us” or “our”) processes personal information about you when we act as a data controller. You can also read about what rights you have in connection with our processing.

2. Spinheroes role as data controller
We process a range of personal data in connection with the operation of our company. We do this, in order to better serve you. Mainly we collect and process general (non-sensitive) data.

If you have any questions concerning our processing of your personal information, you can contact us at any time via contact@spinheroes.info

3. Personal information we collect and its purpose
We process personal information about you in a variety of situations. Read below about our processing under different scenarios.

3.1 Your registration as a new user/player with Spinheroes
When you register as a new user with us, Spinheroes processes personal information about your name, email address, telephone number and any other additional information that you provide to us.

We process personal data for the purpose of fulfilling the agreement with our users concerning the provision of services, invoicing, statistical analysis and quality assurance, as well as to maintain our user registers and provide general services, marketing and sales to our users and potential users.

The basis for our processing is done in accordance with your consent (Article 6 (1) (b) of the Data Protection Regulation)

3.2 Customer service and other forms of communication
When you contact our customer service via email, we record the personal information you provide to us. The purpose of Spinheroes use of this personal information is to service and assist you with your inquiries and process any requests concerning the exercising of your user rights.

Furthermore, the purpose of the processing of personal data is done to further develop, adapt and improve our services and features based on the common preferences and usages of the users. The basis for our processing is done in accordance with your consent (Article 6 (1) (b) of the Data Protection Regulation), or our legitimate interests (Article 6 (1) (f) of the Data Protection Regulation).

3.3 Marketing recipients
When you receive marketing materials from Spinheroes, we process information about your name, email address, telephone number, etc. We also process information about your marketing or communication preferences, and your use of the marketing materials we send to you (including, for example, whether you opened an email from us, whether the email was read, and which links you have opened) as well as any other information that you might have provided to us.

We process your information for the purpose of marketing our business and its products, as well as registering and managing you as a marketing subscriber. Consequently, we send marketing materials that contain information about new services, the latest updates or promotions that we think you might be interested in.

Additionally, we may process your personal information to be cross-promoted to other services or products that we may find relevant or of possible interest.

We use the information concerning your preferences and usage in order to understand the way our customers respond to our marketing, as well as to improve our marketing to you and our other customers going forward.

We will only send marketing materials to you by email, SMS or any other electronic channel when we have obtained your consent for this, when this is required by the rules of the marketing practices act.

We also use data about you to show you content on our own and third-party pages based on your activities and preferences, as well as to limit the number of times you view the same content in order to measure the effectiveness of our content and marketing.

We may also share and disclose your personal information with our Marketing Affiliates for the purpose of providing you with various marketing offers that we or our Marketing Affiliates believe are relevant to you. Our Marketing Affiliates may use this personal information for various marketing procedures, such as direct email and SMS marketing purposes.

You may revoke your consent to receive additional marketing offers from us or our business partners and Marketing Affiliates at any time, by contacting us at contact@spinheroes.info. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and messages.

Our basis for consideration is our legitimate interests (Article 6 (1) (f) of the Data Protection Regulation) and / or your consent (Article 6 (1) (a) of the Data Protection Regulation and section 10 of the Marketing Act).

3.4 Use of Social Media when signing up for Spinheroes services.
When you sign up through your social media account (such as your Facebook account) to use our services or connect your player account to a social media account, we have access to basic personal information from your social media account, e.g. your name, date of birth, profile picture and friend list, as well as information that you have made publicly available on that account.

We process personal data for the purpose of fulfilling the agreement with our users, for the purpose of providing services, statistical analysis and performing quality assurance, and in order to maintain our user registries and provide general service, marketing and sales to our users and potential users.

The basis for our processing is done in accordance with your consent (Article 6 (1) (b) of the Data Protection Regulation), or our legitimate interests (Article 6 (1) (f) of the Data Protection Regulation).

3.8 Other general purposes of processing
We may enrich the information described above with information from other sources. It may be publicly available information – including information that we obtain through commonly available sources. Additionally, information that we have obtained for the purposes described above may be processed by Spinheroes to meet compliance with laws and regulations that Spinheroes is subject to in the course of operating our business or in order to fulfill miscellaneous reporting requirements or information obligations under applicable laws and regulations pertaining to (Article 6 (1) (c) of the Data Protection Regulation).

If Spinheroes sells all or part of our business or sells or transfers our assets, or is otherwise involved in a merger or transfer of all or a substantial part of our business, Spinheroes may transfer your information to that party or the parties involved in the transfer, as part of this transaction whenever it is legally applicable(Article 6 (1) (f) of the Data Protection Regulation).

4. Minors
Our websites and services are not designed or targeted toward persons under 18 years of age. If you are not of legal age, you should not use our services or provide us with personal information.

We reserve the right to access and verify all personal information collected from you. In the case that we become aware of a user who is not of legal age has shared personal information, we may reject and delete such information. If you have any reason to believe that a minor has shared any personal information with us, please contact us at contact@spinheroes.info

5. Sharing of your data with third parties
Spinheroes may disclose your personal information in connection with the normal operation of our business to; other suppliers and/or service providers; to White Label Brands, including any replacement of providers that the White Label Brand may engage to serve White Label Brands; and to our group affiliates.

Additionally, we may disclose personal information to auditors, contractors or advisors related to the Group’s business processes.

Additionally, Spinheroes may disclose your personal information to a public authority in situations where we are obliged to disclose your personal data pursuant to the laws and reporting obligations to which we are subject. We may also disclose personal information related to identity verification and fraud prevention services and other data verifiers to credit reporting agencies, payment providers, payment processors and banks.

We try to limit the disclosure of personal data in any personally identifiable appearance and thus the disclosure of information that can be attributed to you personally.

In addition, Spinheroes also relays your personal information to data processors, for example in connection with the administration of our IT systems and for marketing. Our data processors only process your personal information for our purposes and according to our instructions.

We enter into data processing agreements with our data processors in order to ensure that the necessary security is in place, and in order to protect the information and comply with our data protection obligations.

6. Use of Third-Party Services
By using our websites and services, you may encounter links to third-party websites, services or applications.

Please note that our Privacy Policy does not apply to third-party websites, services or applications, even if they are available, downloaded or otherwise distributed through our website and/or services. This implies that such third-party websites, services or applications are independently responsible for the data and separate from our enterprise. Consequently, we encourage you to carefully read the privacy policies of third-party services and the terms of use of such third-party websites and/or services.

You should always review their privacy practices diligently before providing any personal information to this kind of third party. You will knowingly and voluntarily assume all risks associated with the use of third-party websites, services or applications. You accept that we have no responsibility for such third-party websites and your use of them.

7. Transfer of personal data to non-EU / EEA countries
In connection with our processing of your personal data, we may transfer the information to countries outside the EU / EEA. Data protection legislation in these countries may be more lenient than in Sweden and the rest of the EU / EEA. However, for some countries, the European Commission has determined that the level of data protection is at a level of safeguarding equivalent to the EU / EEA. If we transfer personal data to countries where this is not the case, the transfer of your personal data to those countries outside the EU / EEA will take place on the basis of standard transfer agreements drawn up by the European Commission or other similar transfer agreements that have been specifically designed to ensure a sufficient level of protection.

8. Storage period, data integrity and security
Your personal information will not be stored longer than what is deemed necessary to fulfill the purposes for which it was collected. When your information is no longer needed, we will ensure that it is erased in a secure manner.

If you have registered an account through our websites and services, we will keep your personal data as long as your account is active.

In addition, Spinheroes will keep your personal data as long as it is deemed necessary for us to fulfill our legal obligations under applicable laws, for example, pertaining to; applicable rules for gambling providers and rules concerning money laundering.

It is our policy to protect personal data by applying the necessary technical and organizational security measures.

Information security is the business risk which has the highest priority for Spinheroes. We work seriously and professionally with information security. We have implemented security measures that ensure data protection for all of the personal data we process. We regularly conduct internal follow-ups to gauge the adequacy and compliance of policies and measures.

9. Your rights
As a registered user, you have a number of rights under the Data Protection Regulation. If you would like to exercise your rights, please contact us.

You may – at any time unconditionally – withdraw any consent. This can be done by sending us an email to contact@spinheroes.info. Withdrawing your consent will have no adverse effect. However, it may result in that we will be unable to meet specific requests from you in the future. Withdrawal of your consent will not affect the legality of the treatment on the basis of consent before withdrawal. Furthermore, it will not affect any processing performed on any other legal basis.

You may also – at any time unconditionally – object to our processing when it is based on our legitimate interest.

Your rights also apply to the following:

Right to insight: You have the right to gain access to the personal data that we process about you.
Right to Correction: You have the right to have incorrect personal data about yourself corrected and incomplete personal data completed.
Right to deletion (right to be forgotten): In special cases, you have the right to have your personal data deleted prior to the time when we usually will delete your information.
Right to restrict processing: In some cases, you have the right to have the processing of your personal data restricted. If you have the right to have limited processing, we may only in the future process the information – other than storage – with your consent, or for the purpose of establishing, asserting or defending legal claims, or to protect a person or important public interest.
Right to object: In some cases, you have the right to object to our processing of your personal data, and always the case, if the processing is done for direct marketing purposes.
Right to data portability: In some cases, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have this personal data transferred from one data controller to another.
Right to file a complaint: You can, at any time, file a complaint with the Data Inspectorate regarding our processing of personal data.

10 Updates
We constantly review and update this Privacy Policy. It is, therefore a good idea to consult it regularly. At the top of the page, you will be able to see when it was last updated. The latest version will always be made available on our websites.

11. Cookies policy
Below you can read how Spinheroes uses its own and third-party cookies to analyze how our online activities are carried out.

Some pages from Spinheroes have content that can only be viewed if cookies have been stored. Cookie data is also used to collect personally identifiable information for marketing purposes.

A cookie is a small text file that is stored in the web browser on your computer, smartphone, iPad or whatever device you use to browse the web when you visit websites. Cookies make it possible to recognize your device and gather information about your conduct on the web, including which pages and features are visited with your browser, as well as ensuring that it works technically.

In some cases, cookies are the only way to make a website work as intended. A cookie is a passive file, and consequently, it cannot collect information from your computer nor spread computer viruses or other malicious programs. It is anonymous and contains no personal information. Cookies are used by virtually all websites.

Our basis for processing is consent (cf. Article 6 (1) (a) of the Data Protection Regulation), our legitimate interests (Article 6 (1) (f) of the Data Protection Regulation, and section 3 of the Cookie Order).

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