Privacy Policy

This Privacy Policy explains how spinsamurai, exclusively operating via spinsamurais.com, manages your personal information. It is necessary to have a Privacy Policy to inform players and website visitors of their data rights and the ways their information is collected, processed, and protected, particularly in accordance with applicable Australian (AU) privacy laws and industry standards. This Policy applies to all users interacting with spinsamurais.com and is effective as of 1 January 2025.

Who We Are

OBSERVE: Review of operational, regulatory, and contact details per corporate disclosures.
EXPAND: Integration of all legal entity and compliance officer data for AU users.
REFLECT: Presentation of verifiable identification and communication channels for legal transparency.

Operator: spinsamurai is managed and operated exclusively through spinsamurais.com by Dama N.V., a company registered under the laws of Curaçao with registration number 152125. The legal address is Scharlooweg 39, Willemstad, Curaçao.
Licensing & Regulatory Oversight: Dama N.V. holds remote gaming licenses 8048/JAZ2020-013 (Antillephone N.V.) and OGL/2023/174/0082 (Curaçao Gaming Control Board), both valid and prolonged until at least 2025. These licenses regulate the lawful provision of online gambling services; spinsamurai's operation is aligned with Australian data privacy expectations, even though AU is a restricted market.
Contact for Data Protection: For privacy inquiries or concerns, users may contact our Data Protection Officer:
- Name: Matthew Wallace
- Email: Please use our official website contact form at spinsamurais.com
- Registered Office: Scharlooweg 39, Willemstad, Curaçao

What Personal Data We Collect

OBSERVE: Enumeration of all data types gathered through the platform.
EXPAND: Identification of data categories pertinent to AU law, online gaming, and user interactions.
REFLECT: Structuring of data taxonomy for full transparency and compliance.

Identity Data: Such as full name, date of birth, postal and residential address, and government-issued identification documents as required under Know-Your-Customer (KYC) obligations.
Contact Data: Email address, phone number, and other contact information provided via registration or support.
Technical Data: IP address, browser information, device characteristics, operating system version, logs of website usage, and connection timestamps.
Payment and Financial Data: Bank account details, electronic wallet data, credit/debit card information, transaction histories, and withdrawal or deposit records.
Behavioral Data: Betting history, account activity, gaming statistics, interaction logs (e.g., time spent, pages accessed), and clickstream analysis.
Cookies & Similar Technologies: Information collected through session cookies, persistent cookies, and third-party analytics or advertising tools, further detailed below.
Communication Data: Records of customer service interactions, complaint forms, and other user-generated communications with spinsamurai via spinsamurais.com.

Legal Basis for Processing

OBSERVE: Scrutiny of lawful grounds for data processing within the online gambling context and AU requirements.
EXPAND: Recognition of explicit and implicit processing justifications relevant to user and regulatory interests.
REFLECT: Categorical disclosure of legal basis in accordance with the Privacy Act 1988 (Cth), AU APPs, and Curaçao obligations.

User Consent: Obtained where required for specific processing activities, such as direct marketing and non-essential cookies. Users may withdraw consent at any time via site options.
Performance of a Contract: Processing is required to establish and manage your account, verify your identity, process deposits and withdrawals, and provide casino services in accordance with the terms and conditions of spinsamurais.com.
Legal Obligations: Compliance with applicable anti-money laundering (AML), counter-terrorism financing (CTF), KYC, record-keeping, and reporting requirements imposed by gaming authorities and financial regulators.
Legitimate Interests: To safeguard website integrity, prevent fraud, conduct analytics for service improvement, and ensure responsible gambling practices, always carefully balanced against your privacy rights under applicable AU law.

Regional Compliance Note: All data processing activities are aligned to ensure legal defensibility under both Curaçao and AU data protection frameworks relevant to online gambling operations.

Purpose of Processing

OBSERVE: Identification of operational needs driving data use.
EXPAND: Mapping between user interactions, regulatory obligations, and data processing objectives.
REFLECT: Synthesis into a comprehensive, purpose-limited statement.

Service Provision: To create, verify, and administer user accounts; facilitate legal participation in games; and process financial transactions via spinsamurais.com.
Compliance & Security: To fulfill legal, licensing, AML/CTF, and KYC obligations, as well as to monitor for fraud, abuse, underage gambling, or suspicious activity.
Customer Support: To respond to user requests, complaints, and inquiries, ensuring high-quality service and dispute resolution.
Service Improvement & Analytics: To operate, optimize, and enhance spinsamurais.com through analysis of aggregate user data and site performance metrics.
Marketing & Promotions: With your explicit consent, to deliver offers, updates, bonuses, and newsletters; users maintain the right to withdraw consent at any time.
Legal Defense: To establish, exercise, or defend legal claims in accordance with applicable law.

Disclosure & Sharing

OBSERVE: Analysis of data sharing relationships and necessary disclosures.
EXPAND: Identification of all categories of third parties and legal bases for transfers.
REFLECT: Transparent disclosure balancing user privacy with regulatory and operational obligations.

Payment & Financial Partners: Sharing of relevant information with banks, payment processors, and e-wallet providers as needed for deposit and withdrawal facilitation.
Technology & Service Providers: Engagement with trusted IT infrastructure, hosting, software, analytics, auditing, and security vendors under confidentiality agreements and subject to compliance requirements.
Regulatory Authorities: Disclosure of data to regulators, law enforcement, or gaming authorities upon lawful request or as required to comply with applicable laws and licensing conditions.
Affiliates & Advertising Networks: Limited data shared for marketing or referral programs, always contingent on user consent and in compliance with AU privacy principles.
Corporate Transactions: In the context of mergers, acquisitions, or restructuring, user data may be shared strictly in accordance with applicable legal and privacy frameworks.

Protective Clause: All data disclosures are limited to what is strictly necessary, with contractual and technical safeguards in place to prevent unauthorized access, use, or disclosure.

International Transfers

OBSERVE: Identify cross-border data flows resulting from Curaçao-based operations and global service providers.
EXPAND: Assess guarantees required under AU law for international data movement.
REFLECT: Assurance of lawful transfer protocols and protective measures.

Data Location: Personal information may be stored or processed on servers located outside of Australia, including but not limited to Curaçao and the European Economic Area (EEA), due to the international structure of spinsamurai's operations.
Transfer Protections: All transfers are subject to adequate protections such as data processing agreements, standard contractual clauses approved under international privacy frameworks, and industry-standard security measures.
User Rights: Despite cross-border data transfers, spinsamurai ensures that your information receives an equivalent standard of protection consistent with the Australian Privacy Principles and applicable international best practices.

Protective Clause: spinsamurai contracts only with third parties demonstrating requisite data protection standards and regulatory compliance, and routinely audits these relationships.

Data Retention

OBSERVE: Determination of statutory and operational retention requirements for all categories of data.
EXPAND: Consideration of AU obligations, anti-fraud, regulatory licensing, and user rights frameworks.
REFLECT: Commitment to time-limited storage and timely erasure.

Personal Data Retention: spinsamurai retains personal and account-related data for no longer than five (5) years following account closure, transaction completion, or final interaction, unless longer retention is mandated by law or regulatory requirement.
Technical and Analytical Data: Aggregate technical and behavioral data is retained as long as necessary for system security, fraud monitoring, and service improvement, with regular anonymization or deletion cycles.
Deletion Criteria: Data is deleted or irreversibly anonymized:
- Upon fulfilling the purpose for which it was collected
- Upon user request, provided that no overriding legal obligations exist
- Upon expiration of mandatory statutory retention periods
Suspension of Retention: In the event of disputes or open investigations, relevant data will be retained until permanent resolution.

Regional Compliance Note: spinsamurai strictly observes AU and Curaçao requirements regarding gaming records and financial transaction documentation until minimum 2025, per license conditions.

Your Rights

OBSERVE: Analysis of user entitlements under AU law and general data protection frameworks.
EXPAND: Detailed itemization of actionable rights for users engaging with spinsamurais.com.
REFLECT: Procedural explanation and practical steps.

Right to Access: You may request confirmation of whether spinsamurai holds your personal data, and obtain a copy of such data in a readily usable format.
Right to Rectification: You may request corrections to inaccurate, incomplete, or out-of-date personal data.
Right to Erasure: Subject to regulatory obligations, you can request deletion of your personal data where processing is no longer necessary or consent has been withdrawn.
Right to Restrict Processing: Under certain circumstances, you may ask to limit the use and processing of your information.
Right to Object: You may object to the processing of data for direct marketing or other specific purposes.
Right to Data Portability: Where technically feasible, you may obtain and transfer your data to another service provider.
Right to Withdraw Consent: You may revoke consent to marketing or non-essential cookies at any time using account preferences or relevant website mechanisms.

Procedural Note: To exercise any of these rights please contact the Data Protection Officer as indicated below. Proof of identity may be required to safeguard your privacy and security.

Cookies & Tracking Technologies

OBSERVE: Categorization of employed tracking technologies and documentation of purposes.
EXPAND: Specification of user options for cookie management in compliance with AU best practice.
REFLECT: Practical controls and transparent technical summaries.

Session Cookies: Temporary files essential for secure user login, account management, and navigation on spinsamurais.com; deleted at session end.
Persistent Cookies: Stored for enhanced user experience, remembering language preferences and site settings up to 12 months, or as detailed in cookie banner documentation.
Third-Party Cookies: Used by analytics providers (e.g., Google Analytics) and advertising networks to measure site performance, customize marketing, and track aggregate behavioral trends, always pursuant to your consent.

Cookie Purposes: For core site functionality, analytics, marketing, fraud prevention, and compliance verification.

Managing Cookies: Most browsers enable users to manage or restrict cookies through settings; users may also opt out through internal account options or via our cookie notice panel. Disabling certain cookies may affect full functionality of spinsamurais.com services.

Data Security

OBSERVE: Systematic review of information security measures in place.
EXPAND: Articulation of technical and organizational safeguards consistent with AU and Curaçao requirements.
REFLECT: Communication of ongoing risk management and user data protection practices.

SSL Encryption: All sensitive data transmissions between your browser and spinsamurais.com servers are protected using up-to-date Secure Socket Layer (SSL) encryption protocols.
Access Controls: Personal data is accessible only to authorized personnel subject to strict authentication and role-based access controls.
Data Storage Security: Electronic records stored on secure servers with state-of-the-art firewalls, intrusion detection, and 24/7 monitoring.
Organizational Measures: Regular third-party security audits, vulnerability assessments, and compulsory staff privacy training to mitigate risks of unauthorized access or disclosure.
Incident Response: Documented procedures for immediate notification and resolution of any detected data incident or breach, in alignment with AU Notifiable Data Breaches (NDB) Scheme and international standards.

Protective Clause: spinsamurai undertakes to continuously monitor, test, and upgrade security systems to ensure robust protection of user data through at least 2025 and beyond.

Complaints & Contacts

OBSERVE: Confirmation of user access channels for privacy issues.
EXPAND: Outline of the internal and external complaint escalation process in accordance with AU legal expectations.
REFLECT: Clear pathways for redress and communication.

Contact for Data Issues: To submit questions, requests, or complaints regarding your data or privacy rights, please contact the spinsamurai Data Protection Officer:
- Name: Matthew Wallace
- Contact Method: Please use the feedback form available at spinsamurais.com
- Office Address: Scharlooweg 39, Willemstad, Curaçao
Internal Procedure: spinsamurai commits to investigating and responding to privacy complaints within 30 days of receipt. Where necessary, your issue will be escalated to relevant legal, compliance, or technical personnel for review.
Regulatory Escalation: If you are dissatisfied with how your complaint is handled, you may also lodge a complaint with the Office of the Australian Information Commissioner (OAIC) or equivalent authority.

Updates

OBSERVE: Ensure routine reassessment and user notification of policy changes.
EXPAND: Specification of notification modalities as per industry standards.
REFLECT: Clear timestamping and user transparency for future changes.

Policy Amendments: spinsamurai reserves the right to modify or update this Privacy Policy at any time to reflect changes in legal requirements, operational practices, or technological advancement.
User Notification: Users will be notified of material changes via website updates, direct electronic communication, or site banners.
Effective Date: The most current version is always available at spinsamurais.com. Users are encouraged to review it periodically.
Last Update: This Policy was last revised on 1 January 2025.