Privacy Policy

Contact Us

You can contact us regarding this Privacy Policy for the following purposes:

• Confirm Personal Information: Verify the accuracy of the personal data we have collected about you.
• Enquire About Data Use: Understand how your personal data is used.
• Opt-Out of Marketing: Prohibit future use of your data for direct marketing purposes.
• Access Your Data: Request a copy of the personal information we hold about you.
• Update or Rectify Data: Correct or update any information you have provided (with supporting evidence, if required).

You can manage your marketing preferences directly in your account settings at neospin.com/profile.

For all requests, contact us via the following methods:

• Email: [email protected]
• Live Chat: Available on NEOSPIN
• Data Protection Officer Email: [email protected]

Please note that emails may occasionally end up in spam folders or fail to reach us due to technical issues. If your query remains unanswered after 10 days, we recommend following up using an alternative method of communication.

For privacy-related issues such as perceived violations, delayed responses to data requests, or clarification of this Policy, you can contact the Data Protection Officer at [email protected].

Information We Collect

We collect and process the following categories of information:

Information You Provide:

Data submitted during registration, deposits, gameplay, or withdrawals. Participation in chat rooms, promotions, or due diligence documentation.

• Name, username, address, date of birth, country, email, phone number.
• Financial and credit card information, identification documents, and proof of funds.

Technical Information:

• IP address, browser type and version, time zone settings, and plugins.
• Details about your visits (e.g., URLs, cookies). Refer to the Cookie Policy for more information.

Gameplay Information:

• Details of games played, time spent, page interactions, and related activities.

Analytics Information:

• Data about your use of the services, such as user activity, errors, timestamps, and browsing patterns.

Information from Other Sources:

• Data from other websites or services operated by our Group.
• Third-party data processors, partners, advertisers, and credit reference agencies.

Categories of Data We Store

• Identity Data: First name, last name, username, date of birth, gender, and email.
• Contact Data: Residential address, phone number, and other communication methods.
• Financial Data: Details about income, sources of funds, bank accounts, payment cards, and documents collected for KYC purposes.
• Transaction Data: Deposits, withdrawals, wagering details, and game activity.
• Technical Data: IP address, browser details, operating system, and login activity.
• Usage Data: Website activity, game history, promotions claimed, and responsible gaming limits.
• Marketing Data: Preferences for receiving marketing materials and communication methods.
• Special Categories of Personal Data: Responsible gaming information, such as data related to medical conditions; racial or ethnic origin (from uploaded documents).

How We Use Information

We process your personal data to:

• Facilitate account creation, gameplay, and transactions.
• Fulfill legal and regulatory obligations, including Anti-Money Laundering (AML) and Responsible Gambling requirements.
• Send promotional materials based on your consent (configurable via account settings).
• Conduct statistical and analytics research to improve our services.
• Collaborate with third-party service providers for technical, marketing, and payment services.

Your Rights

You have the following rights regarding your personal data:

• Access: Request a copy of the data we hold.
• Correction: Update incomplete or incorrect data.
• Erasure: Request deletion of data, where legally permissible.
• Objection: Challenge processing based on legitimate interests.
• Restriction: Temporarily suspend data processing under specific conditions.
• Portability: Receive data in a structured, machine-readable format.
• Withdraw Consent: Opt out of processing based on your prior consent.

To exercise your rights, contact us via the methods listed above. Requests are processed within one month, with extensions for complex cases.

Data Sharing and Processors

We may collaborate with trusted third parties to provide services, including:

• Business Partners: Sub-contractors, marketing providers, and payment processors.
• Analytics Providers: Help us understand user behavior.
• Advertisers: Deliver personalized content.

These processors follow our written instructions and are contractually obligated to protect your data.

Retention and Security

Retention:

Personal data is stored as required by law. For AML compliance, data is retained for at least five years following the last transaction or account closure. Requests for deletion before this period cannot be fulfilled.

Security:

We take reasonable precautions to safeguard your data. Player accounts are protected by unique credentials and optional two-factor authentication (2FA).

If you have any further questions, please contact us at [email protected] or via Live Chat.

How We Use Your Information

1. Information You Provide to Us

We use the information you provide for the following purposes:

• Provision of Services:
  • Fulfill obligations under the Terms and Conditions, including enabling gaming services, processing deposits and withdrawals, managing fraud, and addressing queries or complaints.
• Marketing Communication (with Consent):
  • Provide information about services, bonus schemes, and promotions.
  • Notify you of products and promotions from related sites operated by the Group or its brands.
• Customized Advertising: Tailor advertisements on the site based on your usage and interaction with our platform.
• Service Updates: Notify you about changes or updates to our services.
• Legal Obligations: Comply with Anti-Money Laundering (AML) legislation and other applicable laws.

2. Information We Collect About You

This information is used for the following purposes:

• Website Administration and Performance:
  • Troubleshooting, data analysis, testing, research, statistical, and survey purposes.
  • Information is often collected through cookies (refer to our Cookie Policy for details on managing cookies).
• Marketing Communication (with Consent):
  • Share information about services, bonuses, and promotions.
  • Notify you of promotions offered by the brand you registered with or its partners.
• Fraud and Risk Management:
  • Assign risk profiles or statuses to accounts.
  • Maintain a register of bonus abusers and prevent their participation in future promotions.
  • Screen transactions and behaviors for responsible gambling to ensure safe and entertaining interaction.
• Behavioral Analysis:
  • Build detailed customer profiles based on your site interactions.
  • Monitor responsible gambling behaviors and identify potential problem gamblers through scores and questionnaires.
  • Conduct AML analysis and risk scoring, including comparisons with third-party data sources.
  • Note: Profiling is partially automated, with human oversight on final decisions. Specific profiling logic is not disclosed to avoid compromising compliance and business protection mechanisms.
• Site Improvements: Optimize content presentation for effective user engagement.
• Interactive Features: Enable participation in interactive site features.
• Safety and Security: Enhance the security and safety of the site.
• Advertising Effectiveness: Measure the impact of advertisements and deliver relevant promotions.
• Recommendations: Provide personalized suggestions and recommendations for products or services.
• Aggregated Data:
  • Aggregate data (statistical or demographic) for analysis or service improvement. Aggregated data is not considered personal unless combined with personal data, in which case it will be treated as personal data under this policy.

3. Information We Receive from Other Sources

We may combine data from other sources with the information you provide and collect. This includes:

• Third-Party Verification Services:
  • Age, identity, and address verification tools.
  • Regulators and databases of problem gamblers.
  • Providers of Politically Exposed Person (PEP) and sanctions checks.
• Internal Group Information:
  • Information collected from other sites operated by the Group may be combined to enhance services and prevent access by bonus abusers or problem gamblers.

This combined data supports the purposes outlined above, including ensuring compliance, improving services, and maintaining the integrity of our platform.

Lawful Basis for Processing Personal Data

The table below outlines how we collect and use your personal data, the purposes of such use, and the legal basis upon which processing occurs. Where appropriate, we have also identified legitimate interests involved.

Data Collected	How Data is Collected	Purpose for Collection	Legal Basis for Processing
Identification Data	Requested during registration	1. Customer identification and unique profile creation. 2. Customer verification for Anti-Money Laundering (AML) purposes. 3. Identification during contact.	1. Performance of contract. 2. Legal obligation. 3. Performance of contract.
Contact Details	Requested during registration and/or KYC procedure	1. Customer identification and profile creation. 2. Contacting for support. 3. Sending marketing material of the brand. 4. Sending marketing material of other Group brands. 5. Verification of player identity.	1. Performance of contract. 2. Performance of contract. 3. Legitimate interest. 4. Consent. 5. Legal obligation.
Verification Data	Uploaded to player profile or requested via email/pop-up	1. Verification of identity. 2. Compliance with AML laws.	1. Legal obligation. 2. Legal obligation.
Financial Data	Collected during deposits, withdrawals, or support communication (email, chat, call)	1. Facilitate deposits and withdrawals. 2. Perform KYC checks. 3. Prevent cybercrime. 4. Ensure closed-loop policy compliance.	1. Performance of contract. 2. Legal obligation. 3. Legitimate interest. 4. Legal obligation.
Transaction Data	Automatically generated during deposits and withdrawals	1. Provide gaming services. 2. Compliance with AML laws and gaming license requirements. 3. Monitor activity for social responsibility measures.	1. Performance of contract. 2. Legal obligation. 3. Legal obligation.
Gaming Data	Automatically generated during gameplay	1. Provide gaming services. 2. Compliance with remote gaming laws.	1. Performance of contract. 2. Legal obligation.
Communication Data	Generated through email, live chat, and phone calls (may be recorded)	1. Respond to queries and provide support. 2. Manage risks, obtain professional advice, and establish/defend legal claims.	1. Performance of contract. 2. Legitimate interest.
Profile Data	Generated through gameplay or cookies	1. Service improvement through aggregated/anonymized data. 2. Personalization of user experience. 3. AML/social responsibility segmentation. 4. Targeted marketing.	1. Legitimate interest (aggregated data). 2. Consent. 3. Legal obligation. 4. Consent.
Responsible Gaming Data	Collected through self-assessment tests	1. Profiling for responsible gaming. 2. Investigating gaming activity for responsible gambling.	1. Legal obligation. 2. Legitimate interest.
Technical Data	Automatically collected (e.g., IP address, login details, browser information)	1. Detect restricted/high-risk countries. 2. Prevent abuse (e.g., bonuses, VPN/proxy usage). 3. Improve website functionality and troubleshoot issues.	1. Legal obligation. 2. Legitimate interest. 3. Legitimate interest.
Usage Data	Automatically collected through website interactions	1. Enhance website functionality and user experience. 2. Measure the effectiveness of content and services.	1. Legitimate interest.
RTP Data	Automatically generated during gameplay	1. Compliance with RTP requirements for gaming services.	1. Legal obligation.
Cookie Data	Collected through cookies (refer to the Cookie Policy for details)	1. Improve website performance. 2. Analyze user interactions. 3. Provide personalized services.	1. Legitimate interest.

Additional Notes:

• Profiling: Certain data, including gaming habits and responsible gaming assessments, may involve automated profiling with human oversight for final decisions.
• AML Compliance: Processing data for AML purposes aligns with the Anti-Money Laundering Directive (EU) 2015/849.
• Consent Management: You can modify consent preferences for marketing communications and personalized services via your account settings.

Sharing of Data

To provide our services as outlined in this Privacy Policy, we may need to share your personal data with trusted third parties. These include:

1. Group Entities

Purpose:

• Share data with other Group entities for fraud prevention, bonus abuse detection, AML compliance, and Responsible Gaming obligations.
• Allow other Group entities to contact you about their products and services (with your consent).

Data Shared: Information related to your account, transactions, and gaming activity.

2. Employees of the Company

Purpose: Employees such as the Data Protection Officer, Money Laundering Officer, Customer Support Agents, and VIP Player Managers may access your data to fulfill their roles and provide requested services.

Security: All employees with access to your personal information sign confidentiality agreements to protect your data.

3. Game Providers

Purpose: Game providers may access certain data attributes (e.g., username, IP address) to deliver games on our Website.

4. Payment Providers

Purpose: Share data with payment providers for deposits, withdrawals, and transaction processing.

5. Marketing Partners

Purpose: Share contact information with marketing partners (with your consent) to send promotional emails, SMS, direct mail, or make calls regarding marketing campaigns.

6. Governmental or Regulatory Authorities

Purpose: Provide data when required by law to law enforcement, courts, or regulatory organizations.

7. Communication Software Providers

Purpose: Use third-party tools to facilitate email communication and live chat support.

8. Verification and Compliance Tools

Purpose: Use third-party software for AML checks, age verification, and fraud detection.

9. Business Restructuring

Purpose: If the Company undergoes a merger, acquisition, or partial acquisition, customer data may be transferred to the new entity.

10. Legal and Advisory Services

Purpose: Share data with legal advisors and consultants to manage risks, obtain advice, or establish and defend legal claims.

11. Data Protection Safeguards

Security Measures: Third parties are bound by strict data protection agreements to ensure lawful processing of your data. We strive to minimize data shared and ensure it is processed solely for necessary purposes.

Transfers of Data Outside the EEA

Your personal data may be transferred outside the European Union (EU), European Free Trade Association (EFTA), or European Economic Area (EEA) for:

• Processing bets and transactions.
• Providing requested services.
• Performing verification checks.

Safeguards:

• Use of European Commission’s Standard Contractual Clauses for data protection.
• Ensuring compliance with GDPR and secure handling of data during transfers.

By using our Website, you consent to these data transfers and safeguards.

Data Retention

We retain personal data only as long as necessary for its purpose, considering:

• Legal, accounting, and regulatory requirements.
• Nature and sensitivity of the data.
• Risks associated with unauthorized use or disclosure.

Retention Periods:

• Player data is retained for a minimum of five years after account closure or last transaction due to AML obligations in EU gaming jurisdictions.
• Requests for erasure within this period cannot be fulfilled.
• Anonymized data may be retained indefinitely for research and service improvement.

Your Rights

As a data subject, you have the following rights under data protection law:

• Access: Request a free copy of your personal data.
• Correction: Request corrections to incomplete or incorrect data (supporting evidence may be required).
• Erasure: Request deletion of your data where legal grounds no longer exist for its processing.
• Objection: Object to processing based on legitimate interests if it impacts your rights and freedoms.
• Restriction: Request a temporary suspension of data processing in specific cases.
• Portability: Request your data in a machine-readable format to transfer to another controller.
• Withdraw Consent: Withdraw consent for data processing (e.g., marketing preferences).
• Lodge Complaints: File complaints with a supervisory authority.

Verification: We may request additional information to verify your identity before fulfilling requests.

Response Time: We aim to respond to all legitimate requests within one month. Complex requests may require additional time, and we will keep you informed of any delays.

Automated Decision-Making

We generally do not use fully automated decision-making in our business relationship. If implemented, we will inform you separately as required by law.

Security of Your Data

We adhere to strict data protection practices and ensure secure handling of your information:

Measures in Place:

• Prevent unauthorized access, loss, or misuse of data.
• Limit access to data only to employees, agents, or third parties with a business need.

Account Security:

Player accounts are secured by unique credentials and optional two-factor authentication (2FA). You are responsible for keeping your login details confidential.

We continually review and update our security measures to protect your personal information.