Privacy Policy — 3spin Philippines

Welcome to 3spin's Privacy Policy. 3spin ("we," "us," or "our") operates 3spin.app, a PAGCOR-regulated online casino and sports betting platform designed for Filipino players across the Philippines. This Privacy Policy describes in detail how 3spin collects, uses, stores, discloses, and protects the personal information you provide when you access or use our platform.

We are committed to protecting the privacy of every player who registers and plays on 3spin. This commitment is not just about compliance — it reflects the trust Filipino players place in us when they share their personal details to create an account, complete KYC verification, and conduct financial transactions on our platform.

This Privacy Policy should be read alongside our Terms & Conditions, which together form the complete legal agreement between you and 3spin. If you do not agree with the terms of this Privacy Policy, please do not access or use the 3spin platform.

If you have questions about this policy or wish to exercise any of your data rights, you can reach our Data Protection Officer at any time. Contact details are provided in Section 15 of this document.

3spin collects personal data that is necessary for the operation of our services, fulfilment of regulatory obligations, and delivery of a secure and personalised gaming experience. The categories of personal data we collect include:

We only collect data that is adequate, relevant, and limited to what is necessary for the specific purposes set out in this policy. We do not collect sensitive personal information such as health data, political opinions, or religious beliefs unless you voluntarily provide such information and it becomes relevant to a specific regulatory matter.

3spin collects personal data through several channels in the normal course of operating our platform:

• Direct Registration: When you create a 3spin account, you provide identity data, contact data, and account credentials directly through our registration form.
• KYC Submission: When you submit identity documents for verification — required before withdrawals are processed — we collect copies of your government-issued IDs and proof of address or payment method.
• Payment Transactions: When you make a deposit or request a withdrawal using GCash, Maya, BPI, BDO, UnionBank, 7-Eleven Cliqq, USDT TRC20, or Coins.ph, financial data is collected and recorded for each transaction.
• Platform Activity: As you navigate and use 3spin, we automatically collect technical and usage data through our platform systems, including log files, session tracking, and in-game event data.
• Cookies and Tracking Technologies: Our website uses cookies and similar technologies to collect usage data. See Section 7 for a full breakdown of our cookie practices.
• Customer Support Interactions: When you contact us via live chat, email, or any other support channel, we record and store the content of those communications.
• Third-Party Verification Services: We may receive data from third-party KYC verification partners, fraud prevention services, and payment processors to supplement and verify the information you have provided directly.

3spin uses the personal data we collect for the following specific purposes:

• Account Management: To create, maintain, and administer your player account, including login authentication, account settings, and balance management.
• Identity and Age Verification: To verify that you are who you say you are and that you meet the minimum age requirement of 21 years as mandated by PAGCOR regulations for online gambling in the Philippines.
• Service Delivery: To provide access to all 3spin games and features — JILI slots, live casino, sports betting, sabong, bingo, the wheel, and promotions — and to process all associated financial transactions.
• Regulatory Compliance: To fulfil our obligations under PAGCOR's licensing requirements, the Anti-Money Laundering Act (AMLA) of the Philippines, and the Data Privacy Act of 2012.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, money laundering, and other illegal conduct on the platform.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce self-exclusion and deposit limit requests, and comply with PAGCOR's responsible gaming guidelines.
• Customer Support: To respond to your queries, complaints, and support requests, and to maintain records of those interactions for quality assurance and dispute resolution.
• Platform Improvement: To analyse usage patterns, identify technical issues, and improve the performance, features, and overall user experience of the 3spin platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only if you have opted in to receive such communications. You can opt out at any time.
• Legal Proceedings: To establish, exercise, or defend legal claims and to cooperate with law enforcement or regulatory authorities where required by law.

Under the Data Privacy Act of 2012 (RA 10173), 3spin processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 3spin — that is, to operate your account, process transactions, and deliver the gaming services you have signed up for.
• Legal Obligation: Certain processing is required by law, including KYC verification under PAGCOR regulations, AML reporting under the Anti-Money Laundering Act, and age verification requirements.
• Legitimate Interests: We process certain technical and usage data based on our legitimate interests in operating a secure, fraud-free platform and improving our services, provided these interests are not overridden by your data rights.
• Consent: Where we rely on consent — for example, for marketing communications — we will obtain your explicit consent before sending such communications. You have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

If you would like further information about the specific legal basis we apply to any particular processing activity, please contact our Data Protection Officer at the details provided in Section 15.

3spin does not sell, rent, or trade your personal data to third parties. We may, however, share your data with the following categories of recipients in the following limited circumstances:

• Payment Processors: We share relevant financial data with your chosen payment provider (e.g., GCash, Maya, BPI, BDO) solely to process your deposit or withdrawal transaction. Each payment provider operates under its own privacy policy and data protection obligations.
• KYC and Identity Verification Partners: We may engage certified third-party identity verification services to assist in validating your identity documents. These partners are contractually bound to process your data only for the purposes of identity verification and are prohibited from using it for any other purpose.
• Game Software Providers: Our game providers (such as JILI and live casino studios) may receive technical session data necessary to deliver their games within the 3spin platform. These providers do not receive your full personal profile.
• Regulatory Authorities: 3spin is required by PAGCOR regulations and Philippine law to disclose certain player data and transaction records to regulators upon request. We are also required under the AMLA to report suspicious transactions to the Anti-Money Laundering Council (AMLC).
• Law Enforcement: We will disclose personal data to Philippine law enforcement agencies or courts when legally required to do so by court order, subpoena, or other lawful process.
• Professional Advisers: We may share data with legal counsel, auditors, or compliance consultants under obligations of professional confidentiality, strictly for the purpose of obtaining professional advice.
• Business Transfers: In the event that 3spin undergoes a merger, acquisition, or asset sale, your personal data may be transferred to the successor entity. You will be notified of any such transfer and any changes to the applicable privacy policy in advance.

3spin uses cookies and similar tracking technologies on our website and platform. A cookie is a small text file placed on your device when you visit a website. Cookies allow us to recognise your browser, remember your preferences, and collect usage data to improve your experience.

We use the following types of cookies:

• Strictly Necessary Cookies: These cookies are essential for the platform to function. They enable core features like login session management, account security, and game loading. You cannot opt out of these cookies while using the platform.
• Functional Cookies: These cookies remember your preferences — such as your preferred language, display settings, and recently played games — so that the platform behaves consistently across sessions.
• Analytics Cookies: We use analytics tools to understand how players navigate and use the platform. This data is aggregated and anonymised where possible and is used solely for internal platform improvement purposes.
• Security Cookies: These cookies help us detect and prevent fraudulent activity, including session hijacking, bot activity, and multi-account abuse.

3spin does not use cookies to serve third-party advertising on external websites. We do not participate in cross-site tracking networks or sell cookie data to advertisers.

3spin retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

• Active Account Data: Personal data associated with an active player account is retained for the full duration of the account's existence on the 3spin platform.
• Closed Account Data: Following voluntary account closure or termination by 3spin, we retain player data for a minimum period of five (5) years in accordance with PAGCOR licensing requirements and the Anti-Money Laundering Act's record-keeping obligations.
• KYC Documents: Identity documents submitted for KYC verification are retained for at least five (5) years from the date of submission or from the date of the last transaction on the account, whichever is later.
• Financial Transaction Records: All deposit, withdrawal, and betting transaction records are retained for a minimum of five (5) years for AML and regulatory audit purposes.
• Support Communications: Customer support correspondence is retained for three (3) years for quality assurance and dispute resolution purposes.
• Marketing Data: If you have opted out of all marketing communications, we retain a suppression record of your opt-out indefinitely to ensure we do not contact you again.

Once the applicable retention period expires, personal data is securely deleted or anonymised in accordance with our data disposal procedures, unless a longer retention period is required by a specific legal obligation.

3spin implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. Our security framework includes:

• 256-bit SSL/TLS Encryption: All data in transit between your device and our servers is encrypted using industry-standard TLS protocols. You can verify this by the padlock icon in your browser's address bar when accessing 3spin.app.
• Data Encryption at Rest: Sensitive data stored in our databases — including identity documents and financial records — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within 3spin's systems is restricted on a strict need-to-know basis. Staff members are granted access only to the data necessary for their specific role and are required to authenticate using multi-factor authentication.
• Intrusion Detection and Monitoring: Our systems are monitored 24/7 for suspicious activity, including unauthorised access attempts, unusual data queries, and potential security breaches.
• Regular Security Audits: 3spin conducts periodic security assessments and vulnerability scans of our platform infrastructure to identify and address potential weaknesses proactively.
• Staff Training: All 3spin employees and contractors who handle personal data undergo regular data protection training and are bound by confidentiality agreements.

In the event of a data breach that is likely to adversely affect your rights and freedoms, 3spin will notify you and the National Privacy Commission (NPC) of the Philippines within 72 hours of becoming aware of the breach, in accordance with our obligations under RA 10173.

As a data subject under the Data Privacy Act of 2012 (RA 10173) of the Philippines, you have the following rights with respect to your personal data held by 3spin:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfils that right.
• Right of Access: You may request a copy of the personal data we hold about you at any time. We will provide this within 30 days of receiving your verified request.
• Right to Rectification: If any personal data we hold is inaccurate or incomplete, you have the right to request that we correct it. You may also update certain account details directly through your account settings.
• Right to Erasure: You may request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal and regulatory retention obligations (see Section 8).
• Right to Object: You have the right to object to processing based on legitimate interests, and to opt out of direct marketing communications at any time.
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, machine-readable format where this is technically feasible.
• Right to Damages: You are entitled to claim compensation from 3spin if you have suffered damage as a result of our non-compliance with RA 10173.
• Right to File a Complaint: If you believe your data rights have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

3spin is strictly an adult gaming platform. In accordance with PAGCOR regulations, all players must be at least 21 years of age to register and play on 3spin. We do not knowingly collect personal data from individuals under the age of 21.

All registration attempts are subject to age verification procedures. Where we have reason to believe that a registered account belongs to a person under 21, we will immediately suspend the account, conduct an investigation, and take appropriate action — which may include permanent account closure and forfeiture of the account balance in accordance with applicable regulations.

If you are a parent or guardian and you believe that your child under the age of 21 has registered on 3spin or provided us with personal data, please contact us immediately at [email protected]. We will take prompt action to investigate and, where confirmed, delete the data and close the account.

We encourage parents and guardians to use parental control software and to educate their children about responsible and lawful internet use. 3spin supports initiatives to prevent underage access to online gambling platforms in the Philippines.

The 3spin platform may contain links to third-party websites and services, including payment providers and game studios. These third-party sites operate independently of 3spin and have their own privacy policies. 3spin is not responsible for the privacy practices or content of any third-party website you visit via a link from our platform.

We encourage you to review the privacy policies of any third-party sites before providing them with personal data. The inclusion of a link on the 3spin platform does not imply our endorsement of the linked site's privacy practices.

This Privacy Policy applies solely to data collected by 3spin directly through the 3spin.app platform and associated communications. It does not extend to data collected by third parties through their own independent services.

As an online gaming platform, 3spin may process or store certain data on servers or through service providers located outside the Philippines — for example, cloud infrastructure providers or game software vendors based in other jurisdictions. When such cross-border transfers occur, 3spin ensures that appropriate safeguards are in place to protect your personal data in accordance with RA 10173.

Safeguards we apply for cross-border transfers include:

• Transferring data only to countries or organisations that provide an adequate level of data protection, as determined by the National Privacy Commission of the Philippines
• Entering into binding data transfer agreements with international recipients that require them to apply data protection standards equivalent to those required under Philippine law
• Conducting due diligence on the data protection practices of international service providers before engaging their services

If you would like more information about the specific international transfers that may affect your data, please contact our Data Protection Officer.

3spin reserves the right to update, revise, or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. When we make changes, the revised policy will be published on this page with an updated "Last Updated" date at the top.

For material changes — those that meaningfully affect your privacy rights or the way we process your personal data — we will notify registered players via email or in-platform notification at least 14 days before the changes take effect. Your continued use of the 3spin platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how 3spin protects your personal data. The most current version of this policy will always be accessible at 3spin.app/privacy-policy.

If you disagree with any material changes to this Privacy Policy, you may close your account by contacting our support team. Closing your account does not affect the lawfulness of any processing carried out prior to account closure, and data retention obligations under Section 8 continue to apply.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 3spin handles your personal data, please contact our Data Protection Officer using the details below:

We aim to respond to all data privacy enquiries within 5 business days. For formal data subject requests (access, correction, deletion, portability), please include "Data Privacy Request" in the subject line of your email and provide sufficient information to verify your identity.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the independent supervisory authority responsible for enforcing RA 10173. The NPC can be reached through the official Philippine government channels for data privacy complaints.