Privacy policy

Applicable to AskSpinner Philippines

AskSpinner respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how AskSpinner Philippines (“AskSpinner,” the “Platform,” “we,” “us,” or “our”) collects, uses, stores, shares, and protects your personal data when you access or use our services, as well as the rights you may have regarding your personal data.

This Policy applies to the AskSpinner Philippines website, account system, community features, player reviews, Casino complaints, promotions, rewards, and other related features and services.

We process personal data in accordance with applicable data protection laws, including Republic Act No. 10173, the Data Privacy Act of 2012 (“DPA”), and its implementing rules and regulations.

By using AskSpinner, you acknowledge the data processing practices described in this Privacy Policy. Where consent is required by applicable law, we will obtain your consent separately.

1. Information We May Collect

Depending on how you use AskSpinner, we may collect the following categories of information.

1.1 Account and Contact Information

When you create or use an AskSpinner account, or use features that require contact information, we may collect:

• Username;

• Display name or nickname;

• Email address;

• Mobile phone number;

• Profile picture;

• Login and account security information;

• Account creation date;

• Country or region; and

• Other profile information you voluntarily provide.

Depending on the relevant feature, your mobile phone number may be used for account registration or verification, identity and security verification, necessary service notifications, participation in promotions, reward payments or withdrawals, and the prevention of fraud and account abuse.

We only collect and use information that is reasonably necessary to provide the relevant services.

1.2 Community and User Content

When you participate in the AskSpinner community, we may process content that you voluntarily submit, including:

• Posts;

• Comments;

• Casino reviews;

• Game reviews;

• Ratings;

• Likes and other interactions;

• Images or attachments;

• Reports; and

• Other content related to community features.

Posts, comments, usernames, profile pictures, reviews, and certain interactions that you publish publicly may be visible to other users and internet visitors.

You should therefore not publish passwords, OTPs, PINs, full mobile phone numbers, bank or payment information, identification documents, or other unnecessary sensitive personal information in public areas of AskSpinner.

1.3 Complaint Information

If you submit a casino complaint through AskSpinner, we may collect information reasonably necessary to review and process the complaint, including:

• Your AskSpinner username;

• The casino involved;

• Details of your complaint;

• Relevant transaction amounts;

• Dates and times of relevant events;

• Communications with the casino;

• Screenshots of transactions or withdrawal records; and

• Other supporting evidence you voluntarily provide.

Complaint evidence may contain personal information.

Before submitting evidence, you should redact sensitive information that is not necessary to resolve the complaint, including passwords, OTPs, PINs, full phone numbers, complete payment account information, and identification document numbers.

If we believe that submitted materials contain unnecessary sensitive information, we may hide, redact, restrict access to, or request resubmission of those materials.

1.4 Promotions, Rewards, and Withdrawal Information

When you participate in AskSpinner promotions, Diamonds, Coins, Cash Rewards, or other reward programs, we may process:

• Promotion participation records;

• Diamond, Coin, or other reward balances;

• Referral and task completion records;

• Reward redemption records;

• Withdrawal requests and processing status;

• Mobile phone numbers or other payment information necessary to distribute or withdraw rewards; and

• Account, device, and behavioral information reasonably necessary to prevent promotion abuse or fraud.

If a reward is paid through a third-party payment service, we may process information reasonably necessary to complete that transaction.

For example, where a reward is distributed through a supported Philippine electronic wallet or other payment method, we may need to collect the mobile phone number associated with that payment method or other information necessary to complete the payment.

AskSpinner will not ask you to provide the password, OTP, or PIN of your third-party payment account.

1.5 Technical and Device Information

When you access AskSpinner, we may automatically collect certain technical information, including:

• IP address;

• Browser type;

• Operating system;

• Device type;

• Language settings;

• Pages visited;

• Date and time of access;

• Referral source;

• Page interactions;

• Identifiers generated through cookies or similar technologies; and

• Technical data related to website security or unusual activity.

We primarily use this information to operate and secure the Platform, analyze product performance, improve the user experience, and prevent fraud and abuse.

1.6 Third-Party Login and Services

If AskSpinner offers sign-in through Google, Facebook, or another third-party account, we may receive information from that service based on your authorization, such as your name, profile picture, email address, or third-party account identifier.

The information available to us depends on the third-party service, your authorization, and your privacy settings.

Any independent processing of your personal data by the third-party service is governed by that service's own privacy policy.

2. How We Use Your Information

AskSpinner may process personal data where necessary to provide our services, fulfill your requests, obtain your consent, comply with legal obligations, protect the Platform, or on another basis permitted under applicable law.

We may use personal data to:

• Create and maintain AskSpinner accounts;

• Provide login, mobile phone verification, and account security features;

• Send necessary service notifications by email, mobile phone, or other appropriate communication methods;

• Display posts, comments, and player reviews;

• Operate community features;

• Receive and process Casino complaints;

• Contact relevant casinos regarding complaints;

• Operate promotions and reward programs;

• Process reward redemptions and withdrawal requests;

• Provide customer support;

• Detect spam and fraudulent activity;

• Prevent fake accounts, multiple-account abuse, and promotion abuse;

• Moderate content;

• Analyze website and feature usage;

• Improve our products, content, and user experience;

• Diagnose technical problems;

• Protect the legitimate rights and interests of AskSpinner, our users, and third parties; and

• Comply with applicable legal, regulatory, or lawful government requirements.

We will not use your personal data for purposes that are incompatible with the purposes for which it was originally collected unless permitted by applicable law.

3. AI and Automated Processing

AskSpinner may use artificial intelligence and other automated systems to assist with:

• Detecting spam;

• Identifying potentially prohibited content;

• Identifying duplicate or low-quality content;

• Detecting unusual account activity;

• Assisting with content moderation;

• Classifying and organizing complaints or user-submitted information; and

• Improving community safety and operational efficiency.

Automated systems may flag certain content or activity for human review.

Where further judgment is required, AskSpinner may arrange for manual review.

Where automated processing is subject to specific notice, consent, objection, or other requirements under applicable law, we will provide the appropriate mechanisms.

4. Cookies and Similar Technologies

AskSpinner may use cookies, local storage, and similar technologies to operate the Platform and understand how users interact with it.

These technologies may be used to:

• Maintain login sessions;

• Remember user preferences;

• Protect website security;

• Prevent fraud;

• Measure website traffic;

• Analyze page and feature performance;

• Improve the user experience; and

• Measure content or promotional performance.

Some cookies may be necessary for essential Platform functions.

Where consent is legally required for non-essential cookies or similar technologies, we will provide appropriate choices.

For more information about the types of cookies we use, their purposes, and available controls, please refer to our Cookie Policy.

5. Analytics and Statistics

AskSpinner may use internal analytics systems or third-party analytics services to understand Platform usage, including:

• Page views;

• Traffic sources;

• Approximate country or region;

• Device type;

• Page engagement;

• Feature usage; and

• Website performance.

This information helps us understand which content and features are useful to users and improve AskSpinner.

Where reasonably practicable, we may use aggregated or de-identified data for analytics.

6. How We Share Personal Data

AskSpinner does not sell your personal data.

To operate the Platform, we may disclose or make personal data available to the following categories of third parties where reasonably necessary.

6.1 Service Providers

We may use third-party providers for services such as cloud infrastructure, website hosting, SMS or communications, email, analytics, security, content moderation, customer support, and payments.

These providers may process data only to the extent reasonably necessary to provide the relevant services and should be subject to appropriate data protection and security requirements.

For example, if we use a third-party provider to send mobile verification codes or necessary service messages, your mobile phone number may need to be processed by that communications provider.

6.2 Casinos and Complaint-Related Parties

If you voluntarily submit a casino complaint, we may provide the relevant casino or its authorized representative with information or evidence reasonably necessary to address the complaint.

Submitting a complaint does not automatically authorize us to provide the casino with your mobile phone number, complete account information, or personal data unrelated to the complaint.

Where specific contact information is genuinely necessary to address a complaint, we will handle such disclosure in accordance with the circumstances and applicable law.

6.3 Reward and Payment Providers

If you request to redeem an eligible reward for cash or receive it through a third-party payment method, we may provide the relevant payment provider with information necessary to complete the transaction.

This may include the mobile phone number associated with the payment account, transaction amount, transaction identifiers, and other information reasonably necessary to complete the payment.

The relevant payment provider may independently process certain personal data under its own privacy policy.

6.4 Legal and Regulatory Authorities

We may disclose necessary information to government authorities, regulators, courts, or law enforcement agencies where required by applicable law, a valid court order, or another lawful regulatory request.

6.5 Corporate Transactions

If AskSpinner is involved in a merger, acquisition, restructuring, asset transfer, or similar corporate transaction, certain data may be transferred as part of the relevant business assets.

We will continue to protect such personal data as required by applicable law.

7. Third-Party Casinos and External Websites

AskSpinner may contain links to casinos, game providers, PAGCOR, payment providers, and other third-party websites.

When you follow these links and leave AskSpinner, those third parties may independently collect and process your personal data.

AskSpinner does not control the data processing practices of independent third parties.

Their handling of your personal data is governed by their own privacy policies and terms.

We therefore encourage you to review a third party's privacy policy before providing personal information to that party.

8. Affiliate Links

Some links on AskSpinner may be affiliate links.

When you click an affiliate link, we or our partners may use cookies, click identifiers, or similar technologies to record the visit and determine registrations, conversions, or other affiliate outcomes.

Affiliate tracking data may include:

• Time of click;

• Source page;

• Partner identifier;

• Device or browser-related identifiers; and

• Conversion status.

AskSpinner does not automatically receive the mobile phone number, password, OTP, PIN, or complete payment credentials that you provide to a casino merely because you accessed that casino through an affiliate link.

Relevant partners may also process data according to their own privacy policies.

9. International Data Transfers

AskSpinner operates as an internet platform serving users across different countries and regions.

As a result, your personal data may be processed by servers, cloud providers, communications providers, technology providers, or other service providers located outside the Philippines.

Where personal data is processed across borders, we will take reasonable measures required under applicable data protection law to ensure that the data receives appropriate protection.

The location in which data is stored or processed does not reduce our responsibilities under applicable data protection laws.

10. Data Retention

AskSpinner retains personal data only for as long as reasonably necessary to fulfill the relevant processing purposes, comply with legal obligations, resolve disputes, maintain Platform security, or protect legitimate rights and interests.

Retention periods may differ depending on the type of data.

For example:

• Account and contact information may generally be retained while your account remains active;

• Mobile phone numbers may be retained for as long as reasonably necessary for account verification, security, fraud prevention, or related services;

• Community content may be retained while it remains publicly available;

• Complaint materials may be retained while a complaint is being handled and for a reasonable period necessary to maintain case records;

• Reward and withdrawal records may be retained for financial, security, fraud-prevention, or legal purposes; and

• Security logs may be retained for a reasonable period necessary to investigate fraud, attacks, or violations.

When personal data is no longer required, we may delete, anonymize, or otherwise securely dispose of it as appropriate.

11. Data Security

AskSpinner takes reasonable technical, organizational, and administrative measures to protect personal data, which may include:

• Access controls;

• Authentication measures;

• Data transmission safeguards;

• System and server security;

• Logging and unusual-activity monitoring;

• Restrictions on employee and service-provider access; and

• Data backup and recovery measures.

However, no internet service can guarantee absolute security.

You are also responsible for protecting your account password, mobile verification codes, OTPs, PINs, and other authentication information. You should never provide such information to other users or publish it in AskSpinner's public community areas.

If a personal data breach occurs that may affect users' rights and interests, we will take appropriate investigative, containment, remediation, and notification measures as required by applicable law.

12. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012 and other applicable requirements, you may have the following rights.

12.1 Right to Be Informed

You have the right to know whether and how AskSpinner processes your personal data.

12.2 Right of Access

Where applicable, you may request access to personal data held by AskSpinner and relevant information regarding its processing.

12.3 Right to Rectification

If your personal data, including your mobile phone number or other account information, is inaccurate or incomplete, you may request reasonable correction.

12.4 Right to Object

Where applicable, you may object to certain processing of your personal data, including certain processing based on consent, direct marketing, or automated processing.

12.5 Right to Erasure or Blocking

Where provided by law, you may request the deletion, blocking, or cessation of processing of your personal data.

However, we may retain information where reasonably necessary to comply with legal obligations, resolve disputes, prevent fraud, protect legal rights, or for another purpose permitted by law.

12.6 Right to Data Portability

Where applicable, you may request to receive your personal data in a structured and commonly used electronic format.

12.7 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent where applicable.

Withdrawal of consent does not affect the lawfulness of processing performed before the withdrawal.

12.8 Right to File a Complaint

If you believe AskSpinner has violated your data privacy rights, you may contact us regarding your concern.

Under Philippine law, you may also have the right to file a complaint with the National Privacy Commission (“NPC”).

13. Account Deletion

Where AskSpinner provides an account deletion function, you may use that function or contact us to request deletion of your account.

Deleting your account does not necessarily mean that all related data will immediately disappear from every system.

To the extent permitted by law, we may still retain:

• Records necessary to prevent fraud;

• Reward or withdrawal records;

• Necessary records relating to resolved complaints;

• Data that must be retained under legal or regulatory requirements; and

• Information necessary to resolve disputes or protect legal rights.

The treatment of public community content may depend on the nature of the content, your privacy rights, the integrity of discussions involving other users, and applicable law.

Where your mobile phone number is no longer required for any lawful retention purpose, it will be deleted, anonymized, or otherwise handled in accordance with our applicable retention practices.

14. Marketing and Communications

If AskSpinner sends marketing emails, promotional SMS messages, or similar commercial communications in the future, we will obtain any authorization required under applicable law and provide an appropriate method to opt out.

You may use the unsubscribe or other opt-out method we provide to stop receiving non-essential marketing communications.

However, communications directly related to services you are actively using may not constitute marketing communications. These may include:

• Mobile phone or account verification;

• Account security notifications;

• Complaint status updates;

• Promotion participation status;

• Reward redemption or withdrawal status; and

• Important service or policy notices.

We may continue to send necessary service communications while you use the relevant service or feature.

We will not use your mobile phone number for unauthorized marketing merely because you provided it to AskSpinner.

15. Users Under 21

Gambling-related content on AskSpinner Philippines is intended only for users who are 21 years of age or older.

We do not knowingly collect personal data from persons under 21 through services intended for gambling-related users.

If we become aware that an account belongs to a person who does not meet the applicable age requirement, we may restrict or close the account and handle the associated personal data in accordance with applicable law.

16. Public Content

Please remember that AskSpinner includes publicly accessible community features.

Information that you voluntarily publish publicly may be visible to any internet user, including:

• Username or nickname;

• Profile picture;

• Posts;

• Comments;

• Player reviews;

• Public complaint content; and

• Other public community interactions.

Such content may also be indexed by search engines.

Your registered mobile phone number and email address will not be publicly displayed merely because you created an AskSpinner account.

However, if you choose to publish your contact information in a post, comment, complaint, or other public content, that information may become visible to other users, internet visitors, and search engines.

You should therefore avoid publishing information that you do not want to make public.

17. Changes to This Privacy Policy

AskSpinner may update this Privacy Policy due to:

• Changes in law or regulation;

• Changes to Platform features;

• Changes in our data processing practices;

• Technical or security requirements; or

• Business developments.

The latest version will be published on this page, and the “Last Updated” date at the top will be revised accordingly.

If a change materially affects your privacy rights, we will provide additional notice where required by applicable law.

18. Contact Us

If you wish to:

• Ask how we process your personal data;

• Request access to your personal data;

• Correct your personal data;

• Request deletion or blocking of your personal data;

• Object to certain data processing;

• Withdraw applicable consent;

• Exercise other data subjec