PRIVACY POLICY

October 02, 2025

At Spinoramo, we are committed to protecting your privacy and handling your personal information responsibly, in full compliance with the Canada Privacy Act 2020 and its 13 Information Privacy Principles (IPPs). As a free-to-play social gaming platform, we collect minimal data to enhance your experience without any financial transactions or real-money elements. This policy explains how we manage your information, your rights, and our obligations under Canada law.

INFORMATION WE COLLECT

We collect personal information only when necessary and for lawful purposes (IPP 1). This may include:

• Account Details: Name, email address, and date of birth (to verify age ≥18, as required for responsible entertainment under Canada guidelines).
• Usage Data: IP address, device type, and gameplay preferences to improve our platform (anonymized where possible).
• Cookies and Trackers: We use essential cookies for site functionality and analytics (e.g., session management). Non-essential cookies (e.g., for performance tracking) require your consent. No personal data is collected via cookies without notification.

We do not collect sensitive information like financial details, as our platform involves no real currency or stakes.

HOW WE USE YOUR INFORMATION

Your data is used solely to provide and improve our services (IPP 2):

• To create and manage your account.
• To personalize gameplay recommendations in games like Holiday SLOT or A CACCIA.
• For security and fraud prevention.
• To communicate updates or support responses.

We never use your data for marketing without explicit consent.

SHARING YOUR INFORMATION

We do not sell or share your personal information (IPP 11). Limited disclosure may occur:

• To service providers (e.g., cloud hosting) under strict confidentiality agreements.
• If required by Canada law, such as to the Office of the Privacy Commissioner or authorities under the Gambling Act 2003 (for harm minimization checks). No data is shared offshore without equivalent privacy protections (IPP 12).

DATA SECURITY AND STORAGE

We protect your information with reasonable safeguards against loss, misuse, or unauthorized access (IPP 5). Data is stored securely in Canada or compliant jurisdictions and retained only as long as necessary (IPP 9).

YOUR RIGHTS UNDER THE PRIVACY ACT 2020

As a Canada resident, you have the right to:

• Access your personal information (IPP 6) – Request it free of charge via [email protected].
• Correct inaccuracies (IPP 7).
• Complain to the Privacy Commissioner if you believe your privacy has been breached (IPP 13). We respond to requests within 20 working days.

COOKIES AND TRACKING

In compliance with IPP 3 (collection notification), we inform you about cookies upon your first visit. You can manage preferences via our cookie banner. For details, see our Cookie Policy below.

CONTACT US

• Privacy Officer: [email protected]
• Office of the Privacy Commissioner: www.privacy.org.nz

This policy may be updated; changes will be posted here with notice. Continued use constitutes acceptance.