01 Who We Are
This Privacy Policy is issued by PrimeSpin ("we," "us," "our"), the operator of the online gaming platform available at primespin.app. PrimeSpin acts as the data controller for personal information collected through registration, gaming activity, payment transactions, and all other interactions on the platform.
This policy applies to all players who have registered an account with PrimeSpin, visitors who browse the platform without registering, and anyone who contacts us through our support channels. It covers data collected through the PrimeSpin website and any mobile-optimised version of the platform.
If you have questions about how PrimeSpin handles your personal data, you can reach our data privacy team at support@primespin.app. We're committed to responding to privacy-related enquiries promptly.
02 Data We Collect
PrimeSpin collects personal data in the following categories. We only collect information that is necessary for the purposes described in this policy.
Registration & Identity Data
When you create a PrimeSpin account, we collect:
- Full legal name
- Date of birth (to verify you are 18 or older)
- Email address
- Mobile number (Philippine-registered)
- Username and password (stored in hashed form)
Identity Verification Documents
For Know Your Customer (KYC) compliance and to process withdrawals, PrimeSpin may request one or more of the following:
- Government-issued photo ID (UMID, PhilSys ID, passport, driver's licence, voter's ID)
- Proof of address (utility bill, bank statement dated within 90 days)
- Selfie or photo for face verification purposes
Financial & Transaction Data
When you deposit or withdraw, we collect payment method details sufficient to process the transaction — for example, your GCash-registered mobile number or bank account reference. We do not store full card numbers or full GCash credentials.
Gaming Activity Data
We record your betting and gaming history on the platform, including bet amounts, game selections, win/loss outcomes, and session timestamps. This data is used for account management, dispute resolution, and regulatory reporting.
Technical & Device Data
When you access PrimeSpin, we automatically collect technical information including your IP address, browser type, operating system, device model, and general location (country/region level). This is used for security monitoring and platform optimisation.
PrimeSpin handles your personal data with the same care and trust you expect from your neighbourhood sari-sari store — local, reliable, and discreet.
03 How We Use Your Data
PrimeSpin uses your personal data for the following purposes:
| Purpose | Data Used |
|---|---|
| Account creation & management | Name, email, mobile number, date of birth |
| Identity verification (KYC) | ID documents, selfie, proof of address |
| Processing deposits & withdrawals | Payment method details, transaction records |
| Platform security & fraud prevention | IP address, device data, login activity |
| Regulatory compliance & reporting | Identity, transaction, and gaming records |
| Customer support | Contact details, account history, support communications |
| Personalised promotions (with consent) | Gaming activity, preferences, opt-in status |
| Platform improvement | Aggregated, anonymised usage analytics |
PrimeSpin does not use your personal data to make solely automated decisions that produce significant legal or similarly significant effects on you without human review, except in cases of fraud detection where immediate automated action is necessary to protect the platform and other users.
04 Legal Basis for Processing
PrimeSpin processes your personal data on the following legal grounds:
- Contractual necessity: Processing your registration data, payment information, and gaming activity is necessary to provide you with the PrimeSpin platform services you've signed up for.
- Legal obligation: KYC verification, anti-money laundering checks, and regulatory reporting are required by applicable laws and regulations. We have no choice but to collect and retain certain data to fulfil these obligations.
- Legitimate interests: We process technical and device data to maintain platform security, detect fraud, and improve our services. These interests do not override your fundamental privacy rights.
- Consent: Where we send you personalised marketing communications or use non-essential cookies, we do so only with your explicit consent. You can withdraw consent at any time.
From Baguio to Batangas — PrimeSpin's privacy practices protect Filipino players wherever they play.
05 Data Sharing & Third Parties
PrimeSpin does not sell, rent, or trade your personal information. We share data with third parties only in the following circumstances:
Payment Processors
To process your GCash, Maya, bank transfer, or card transactions, we share the minimum necessary payment information with our payment processing partners. These partners are contractually bound to use your data solely for transaction processing purposes.
Identity Verification Providers
For KYC checks, PrimeSpin may use third-party identity verification services. These providers receive your ID documents and verification data under strict data processing agreements and are not permitted to use your information for any other purpose.
Regulatory & Law Enforcement Authorities
We are required to report certain activities and share specific data with gaming regulators, financial intelligence authorities, and law enforcement agencies where mandated by applicable law. We cannot override these legal obligations.
Service Providers
We work with carefully selected service providers for functions such as platform hosting, email delivery, and customer support software. All such providers operate under data processing agreements that restrict their use of your data strictly to the services they provide to PrimeSpin.
06 Cookies & Tracking Technologies
PrimeSpin uses cookies and similar tracking technologies to operate the platform, maintain your session, and understand how players use the site. Here's what we use and why:
Essential Cookies
These cookies are required for the platform to function. They keep you logged in during your session, remember your language and display preferences, and enable secure transactions. You cannot opt out of essential cookies while using PrimeSpin.
Analytics Cookies
With your consent, we use analytics tools to understand how players navigate the platform — which pages are most visited, where users drop off, and how features are used. This data is aggregated and anonymised. We use these insights to improve the PrimeSpin experience.
Security Cookies
Some cookies support our fraud detection and account security systems — for example, identifying unusual login patterns from unfamiliar devices. These operate in the background and are essential for protecting your account.
You can manage your cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to use the core PrimeSpin platform, though some personalisation features may not function as expected.
07 Data Retention
PrimeSpin retains your personal data only for as long as it is necessary for the purposes outlined in this policy, or as required by applicable law.
- Active accounts: Your data is retained for as long as your account remains active on the PrimeSpin platform.
- Closed accounts: Following account closure, we retain identity, transaction, and gaming records for a minimum period required by anti-money laundering regulations and gaming compliance obligations. This is typically five to seven years.
- Support communications: Records of support interactions are retained for a reasonable period to assist with follow-up queries and dispute resolution.
- Marketing data: If you have opted in to marketing communications, your contact details and preferences are retained until you withdraw consent or unsubscribe.
When personal data is no longer required, PrimeSpin securely deletes or anonymises it in accordance with our internal data lifecycle procedures.
PrimeSpin keeps your data as safe as Siargao keeps its waves — protected, natural, and under control.
08 Data Security
PrimeSpin implements appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. Our security practices include:
- SSL/TLS encryption for all data transmitted between your browser and our platform;
- Hashed password storage — your password is never stored in plain text;
- Access controls — internal staff access to personal data is restricted on a need-to-know basis;
- Regular security assessments of platform infrastructure and third-party integrations;
- Anomaly detection systems that flag unusual login patterns and suspicious transactions in real time.
Despite these measures, no online platform can guarantee 100% security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, PrimeSpin will notify affected players and relevant regulatory authorities as required by applicable law.
You also play a role in keeping your account secure. Use a strong, unique password for PrimeSpin, never share your login details, and contact us immediately if you suspect your account has been compromised.
09 Your Data Rights
As a player on PrimeSpin and a data subject under Philippine privacy law, you have the following rights regarding your personal data:
Right to Access
Request a copy of the personal data PrimeSpin holds about you.
Right to Rectification
Ask us to correct inaccurate or incomplete personal data on your account.
Right to Erasure
Request deletion of your data where there is no overriding legal obligation to retain it.
Right to Object
Object to processing of your data for direct marketing or on grounds of legitimate interest.
Right to Restriction
Request that we limit how we use your data while a complaint or correction request is being resolved.
Right to Portability
Receive a copy of data you've provided to PrimeSpin in a machine-readable format.
To exercise any of these rights, contact PrimeSpin at support@primespin.app with your request. We will respond within the timeframe required by applicable law. Identity verification may be required before processing certain requests to protect against unauthorised access.
If you believe PrimeSpin has not handled your personal data in accordance with this policy or applicable law, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.
10 Children's Privacy
PrimeSpin is strictly for adults aged 18 and above. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that a minor has registered an account or provided personal data to us, we will immediately close the account and delete the associated data.
If you are a parent or guardian and believe your child has registered on PrimeSpin, please contact us immediately at support@primespin.app. We take underage gambling prevention extremely seriously and will act promptly on any such report.
11 International Data Transfers
PrimeSpin's core platform infrastructure and primary data storage are operated in a manner designed to serve the Philippine market. In some cases, however, data may be processed by service providers located outside the Philippines — for example, cloud infrastructure providers or KYC technology vendors with international operations.
Where personal data is transferred internationally, PrimeSpin ensures that appropriate safeguards are in place, consistent with the requirements of the Data Privacy Act of 2012. This includes contractual data processing agreements that impose obligations equivalent to those under Philippine law on all international recipients of your data.
By registering with PrimeSpin, you acknowledge and consent to these transfers where they are necessary for the delivery of our services.
12 Policy Updates
This Privacy Policy may be updated from time to time to reflect changes in our data practices, new services offered on the PrimeSpin platform, or updates to applicable laws and regulations.
When we make material changes — changes that significantly affect how we collect or use your personal data — we will notify registered players by email at the address on file and display a prominent notice on the PrimeSpin platform before the changes take effect. The "Last Updated" date at the top of this page will also be revised.
Continued use of the PrimeSpin platform after the effective date of a policy update constitutes your acceptance of the revised terms. We recommend reviewing this policy periodically, especially if you haven't logged in for some time.
13 Contact Us
For any questions, concerns, or requests regarding your personal data and this Privacy Policy, reach out to the PrimeSpin privacy team:
Subject Line Suggestion: "Privacy Request – [Your Username]" for faster routing
Response Time: Within 15 business days for formal data subject requests; faster for general enquiries
We genuinely take privacy seriously at PrimeSpin — not as a legal formality, but because Filipino players deserve to know exactly how their data is handled and to have real control over it. Salamat for trusting us with your information. We don't take that lightly.