PRIVACY POLICY

YOUR DATA NARRATIVE

At Pokies24.io, operated by Spinwise Gaming Limited, we believe your privacy deserves more than a standardized policy—it warrants a comprehensive shield. This Privacy Shield document explains our relationship with your information—how we collect it, why we need it, how we safeguard it, and your control over it.

Think of this as the backstory to your data journey with us. It's designed to provide clarity and confidence as you enjoy our gaming experiences.

This Privacy Shield is inseparable from our Player Contract. Both should be read as companion documents that together form our complete agreement with you.

Last refreshed: May 21, 2025

SECTION 1: DATA COLLECTION SPECTRUM

1.1 Information You Entrust to Us

When you register and use Pokies24.io, you voluntarily share certain identifiers with us:

Essential Identifiers:

  • Full legal name
  • Date of birth
  • Residential address
  • Email address
  • Mobile number
  • Government-issued ID details (during verification)
  • Financial information (payment methods used)

Activity Footprints:

  • Login patterns and session information
  • Transaction history
  • Game preferences and wagering habits
  • Communication records with our support team
  • Device information and technical specifications
  • IP address and geolocation data

Preference Indicators:

  • Marketing preferences
  • Language selections
  • Display customizations
  • Notification settings
  • Self-imposed gaming limits

1.2 Indirect Information Gathering

Beyond what you directly provide, our platform automatically collects:

Technical Signatures:

  • Browser type and version
  • Operating system identification
  • Screen resolution and color depth
  • Device type and model
  • Network performance metrics
  • Crash reports and error messages

Behavioral Patterns:

  • Pages visited and features used
  • Time spent on various sections
  • Navigation pathways through our platform
  • Game session duration and frequency
  • Deposit and withdrawal patterns
  • Response to promotions

Environmental Context:

  • Referring websites or apps
  • Search terms used to find us
  • Third-party authentication when used
  • Time zone and geographic region
  • Connection type (wifi/mobile data)

1.3 The Cookie Ecosystem

Our platform utilizes digital cookies—small data files stored on your device—to enhance your experience:

Functional Cookies: Essential for basic platform operations, login persistence, and session management.

Preference Cookies: Remember your settings, language choices, and customizations.

Analytical Cookies: Help us understand how users interact with our platform, identifying popular features and potential improvements.

Marketing Cookies: Track effectiveness of our promotional campaigns and present tailored offerings.

Security Cookies: Detect unusual activity, protect against unauthorized access, and maintain account integrity.

You can manage cookie preferences through our Cookie Control Center or your browser settings, though disabling certain cookies may limit functionality.

SECTION 2: PURPOSE PATHWAYS

2.1 Core Operational Needs

Your information serves these essential functions:

Account Management:

  • Creating and maintaining your gaming profile
  • Verifying your identity and age
  • Securing your account against unauthorized access
  • Processing your transactions safely
  • Preventing duplicate or fraudulent accounts

Service Delivery:

  • Providing access to your preferred games
  • Processing deposits and withdrawals
  • Calculating and awarding bonuses and rewards
  • Facilitating game history and transaction records
  • Delivering personalized gaming recommendations

Legal Compliance:

  • Age verification (21+ requirement)
  • Anti-money laundering checks
  • Problem gambling prevention
  • Financial transaction monitoring
  • Tax reporting obligations where applicable

2.2 Experience Enhancement Uses

Beyond core operations, we utilize data to improve your experience:

Platform Refinement:

  • Analyzing user behavior to improve interface design
  • Identifying and resolving technical issues
  • Optimizing game performance across devices
  • Developing new features based on usage patterns
  • Testing platform changes with user segments

Personalization Framework:

  • Tailoring game recommendations to your preferences
  • Customizing promotions based on play history
  • Adjusting communication frequency to your engagement
  • Remembering your visual and functional preferences
  • Creating VIP experiences for qualified players

Support Enhancement:

  • Providing context-aware assistance
  • Resolving disputes with complete information
  • Offering proactive help for common issues
  • Training our support team through anonymized cases
  • Developing self-help resources based on common queries

2.3 Communication Channels

Your information enables meaningful interaction through:

Transactional Messaging:

  • Deposit and withdrawal confirmations
  • Account security notifications
  • Identity verification requests
  • Important account updates
  • Responsible gaming reminders

Relationship Communications:

  • Welcome journeys for new members
  • Educational content about platform features
  • Responsible gaming tools and resources
  • Service announcements and platform changes
  • Survey invitations for feedback

Promotional Correspondence:

  • Personalized bonus offers
  • Tournament invitations
  • New game announcements
  • Loyalty program updates
  • Seasonal promotions and events

You can customize which communications you receive through your Account Preferences Center, though transactional messages cannot be disabled as they're essential to service delivery.

SECTION 4: SECURITY ARCHITECTURE

4.1 Technical Safeguards

Your information is protected through multiple security layers:

Data Encryption:

  • TLS 1.3 protocol for all data in transit
  • AES-256 encryption for sensitive stored data
  • Encrypted database fields for personal identifiers
  • Secure key management systems
  • End-to-end encryption for support communications

Infrastructure Protection:

  • DDoS mitigation systems
  • Next-generation firewalls
  • Intrusion detection and prevention systems
  • Regular vulnerability scanning
  • 24/7 security monitoring

Access Controls:

  • Strict role-based access limitations
  • Multi-factor authentication for system access
  • Privileged access management
  • Session timeout enforcement
  • Comprehensive access logging

4.2 Operational Protocols

Beyond technical measures, we employ procedural protections:

Personnel Practices:

  • Background checks for employees with data access
  • Regular security awareness training
  • Confidentiality agreements
  • Least privilege access principles
  • Segregation of duties for sensitive functions

Incident Response:

  • Dedicated security incident response team
  • Documented breach notification procedures
  • Regular incident response drills
  • Digital forensics capabilities
  • Continuous monitoring systems

Compliance Framework:

  • Regular security audits and assessments
  • Penetration testing by independent specialists
  • Compliance with ISO 27001 standards
  • GDPR-aligned data protection practices
  • Gaming authority security requirements

4.3 Data Lifecycle Management

Information protection extends throughout the data lifecycle:

Retention Parameters:

  • Account information: Duration of account plus 5 years
  • Transaction records: 7 years (regulatory requirement)
  • Communication records: 2 years
  • Technical logs: 90 days
  • Marketing preferences: Until changed or account closure

Minimization Principles:

  • Collection limited to necessary information
  • Automated purging of expired data
  • Anonymization of historical data where possible
  • Purpose-specific data access limitations
  • Regular data inventory and classification

Deletion Protocols:

  • Secure erasure methods for digital records
  • Certified destruction of physical documents
  • Verification processes for deletion requests
  • Cascading deletion across systems
  • Retention of proving deletion occurred

SECTION 5: YOUR CONTROL CENTER

5.1 Access Rights

You have comprehensive access to your information through:

Self-Service Portal: Our Account Dashboard provides direct access to view most of your personal information, including profile details, transaction history, game activity, and communication preferences.

Information Requests: For data not visible in your dashboard, you can submit a Subject Access Request through [email protected]. We'll provide a comprehensive export within 30 days.

Verification Requirement: To protect your privacy, all access requests require identity verification through our standard security protocols.

5.2 Modification Capabilities

You can update and correct your information through these channels:

Self-Manageable Information:

  • Contact details
  • Password and security settings
  • Marketing preferences
  • Display and interface settings
  • Responsible gaming limits

Assisted Updates: Some changes require verification through our support team:

  • Legal name corrections
  • Date of birth adjustments
  • Residential address verification
  • Document replacements
  • Payment method changes

Change Limitations: Certain information cannot be altered once verified due to regulatory requirements and integrity measures.

5.3 Your Privacy Choices

You control how your information is used through several mechanisms:

Communication Preferences: Fine-tune which messages you receive through your Communication Control Panel, with separate toggles for:

  • Promotional offers
  • New game announcements
  • Tournament invitations
  • Platform updates
  • Market research participation

Data Use Limitations: You can restrict certain uses of your data, including:

  • Internal analytics participation
  • Personalization features
  • Cross-product marketing
  • Behavioral profiling
  • Third-party feature integration

Account Closure Options: You may choose to:

  • Temporarily deactivate your account
  • Permanently close your account
  • Request data deletion beyond regulatory requirements
  • Export your data before closure
  • Specify marketing contact restrictions post-closure

SECTION 6: INTERNATIONAL DATA MOVEMENT

6.1 Global Operations Framework

Pokies24.io operates within a multinational environment:

Primary Data Residence: Our primary servers and databases are located within the European Union (primarily Ireland and Germany), benefiting from EU data protection standards.

Supplementary Processing Locations: Certain operations may involve data processing in:

  • United Kingdom
  • Switzerland
  • Singapore
  • Canada
  • Australia

Data Localization Compliance: For users in regions with data localization requirements, we maintain regional data storage as required by local laws.

6.2 Transfer Safeguards

When data crosses borders, it's protected by:

Legal Frameworks:

  • Standard Contractual Clauses (SCCs)
  • Binding Corporate Rules where applicable
  • Data Processing Agreements with all partners
  • Adequacy decisions recognition
  • Regional privacy shield certifications

Technical Measures:

  • End-to-end encryption for international transfers
  • Pseudonymization where appropriate
  • Minimized data sets for cross-border sharing
  • Secure transfer protocols
  • Access controls based on jurisdiction

Verification Processes:

  • Regular compliance audits of international partners
  • Data transfer impact assessments
  • Ongoing monitoring of regulatory changes
  • Periodic review of transfer mechanisms
  • Independent verification of safeguard implementation

6.3 Regional Variations

Privacy practices may vary slightly based on your location due to local regulations:

European Region: Enhanced rights under GDPR, including detailed access rights, data portability, and additional consent requirements.

California Residents: Additional rights under CCPA/CPRA, including specific disclosure requirements and opt-out options.

Canadian Members: PIPEDA-specific consent management and purpose limitation protections.

Australian Users: Privacy protections aligned with the Australian Privacy Principles, including particular notification requirements.

Other Jurisdictions: Additional measures as required by your local data protection laws.

SECTION 7: ANALYTICS AND PROFILING

7.1 Analysis Activities

We employ various analytical approaches to understand user experience:

Usage Analysis:

  • Game popularity and engagement patterns
  • Feature adoption and abandonment rates
  • User journey mapping
  • Session length and frequency
  • Conversion pathway analysis

Performance Monitoring:

  • Platform speed and responsiveness
  • Error rate monitoring
  • Device compatibility issues
  • Feature reliability metrics
  • System availability tracking

Trend Identification:

  • Emerging game preferences
  • Changing usage patterns
  • Seasonal variations in activity
  • Response to promotional campaigns
  • New player onboarding optimization

7.2 Responsible Profiling Practices

When we create user profiles, we adhere to these principles:

Transparency:

  • Clear indication when profiling is used
  • Explanation of profile criteria
  • Disclosure of automated decision impacts
  • Purpose specification for profiles
  • Manual review availability for significant decisions

Fairness Measures:

  • Regular bias detection and mitigation
  • Avoidance of discriminatory variables
  • Statistical validity requirements
  • Diverse data sampling
  • Exclusion of protected characteristics

Control Mechanisms:

  • Option to object to profiling
  • Alternative non-profiled experiences
  • Profile access and correction capabilities
  • Limitation of profile persistence
  • Human intervention for consequential decisions

7.3 Responsible Gaming Protection

We use analytics specifically to promote safer gaming:

Pattern Recognition:

  • Early identification of potentially problematic behavior
  • Sudden changes in gaming patterns
  • Escalation of deposit frequency or amounts
  • Session duration outliers
  • Chasing loss behaviors

Intervention Framework:

  • Personalized responsible gaming messaging
  • Tailored tool suggestions
  • Limit setting recommendations
  • Reality check customization
  • Self-assessment prompts

Effectiveness Measurement:

  • Tool adoption tracking
  • Behavior change monitoring
  • Feedback collection on interventions
  • Long-term pattern analysis
  • Continuous improvement of protection measures

SECTION 8: THIRD-PARTY INTEGRATIONS

8.1 External Service Connections

Our platform connects with various third-party services:

Authentication Providers: When you use social login or external authentication, we exchange limited profile information with providers like Google or Apple for verification purposes.

Payment Gateways: Financial transactions involve necessary data sharing with payment processors, banks, and financial service providers.

Game Studios: When playing third-party games, session information and gameplay data are shared with the game provider for functionality and license compliance.

Analytics Tools: We use services like Google Analytics and proprietary tools to understand user behavior, always with appropriate data minimization.

Customer Support Platforms: Support interactions may involve third-party ticketing systems and communication tools operating under our data protection standards.

8.2 External Link Policy

Our platform may contain links to external websites and services:

Boundary Notification: We clearly mark when you're leaving our platform for a third-party site.

Relationship Disclaimer: Links to other sites don't imply endorsement or responsibility for their content or practices.

Independent Policies: Third-party sites operate under their own privacy policies, which we encourage you to review before sharing information.

Seamless Integration Notice: For framed or embedded third-party content, we provide visual indicators and access to relevant privacy information.

Data Sharing Limitations: We do not share your personal information with linked sites unless explicitly disclosed and consented to.

8.3 Social Feature Considerations

When using social or community features within our platform:

Visibility Control: You control which aspects of your profile or activity are visible to other users.

Content Ownership: Any content you generate (comments, reviews, forum posts) is subject to our terms while respecting your intellectual property rights.

Community Moderation: User-generated content is monitored for compliance with our community standards and privacy protections.

Social Sharing Options: Features that allow sharing to external social networks clearly indicate what information will be transferred.

Communication Boundaries: Direct user-to-user communication is governed by consent-based limitations and anti-harassment protections.

SECTION 9: SPECIAL PROTECTION CATEGORIES

9.1 Financial Information Safeguards

Your financial data receives enhanced protection:

Limited Retention:

  • Complete payment card details are never stored
  • Tokenization replaces actual payment information
  • Partial information retained solely for identification
  • Transaction records kept separate from identity data where possible
  • Automated purging of unnecessary financial details

Specialized Security:

  • PCI-DSS compliance for all payment processing
  • Segregated financial data storage
  • Enhanced encryption for financial transactions
  • Strict access limitations for financial records
  • Real-time monitoring for unusual patterns

Financial Privacy Options:

  • Multiple payment method support for privacy preference
  • Cryptocurrency options where legally permitted
  • Optional transaction obfuscation on bank statements
  • Financial record access restrictions
  • Withdrawal method consistency requirements

9.2 Identity Verification Documents

Government-issued IDs and verification documents are handled with exceptional care:

Restricted Processing:

  • Viewed only by authorized verification personnel
  • Automated verification where possible to minimize human access
  • Stored separately from general account information
  • Used exclusively for verification and compliance purposes
  • Never shared with marketing or product development teams

Enhanced Security:

  • Encrypted at rest with higher-grade encryption
  • Watermarked when viewed by staff
  • Access logging with reason documentation
  • Automatic redaction of non-essential information
  • Secure transmission through dedicated channels

Retention Controls:

  • Kept only as long as legally required
  • Subject to accelerated purging protocols
  • Regular review of necessity
  • Maintained in original form only when legally required
  • Otherwise converted to verification outcomes only

9.3 Behavioral Data Protection

Information about your gaming patterns receives special handling:

Responsible Use:

  • Used primarily for responsible gaming initiatives
  • Never exploited to encourage excessive play
  • Analyzed for player protection opportunities
  • Segregated from marketing targeting data
  • Subject to regular ethical review

Access Limitations:

  • Available only to responsible gaming specialists
  • Aggregated and anonymized for broader analysis
  • Individual profiles limited to protective interventions
  • Subject to purpose limitation controls
  • Regular purging of historical patterns

Transparency Practices:

  • Clear disclosure of monitoring for protective purposes
  • Regular responsible gaming communications
  • Tools to view your own behavioral patterns
  • Self-assessment resources
  • Access to explanation of protective interventions

SECTION 10: POLICY EVOLUTION

10.1 Amendment Process

This Privacy Shield evolves through a structured approach:

Revision Triggers:

  • Regulatory landscape changes
  • New feature introductions
  • Changes in data processing activities
  • Enhanced security measures
  • Periodic comprehensive reviews

Update Communication:

  • Email notifications for material changes
  • In-platform alerts
  • Version history availability
  • Summary of key changes
  • Advance notice when possible

Consent Considerations:

  • New consent collection for material changes
  • Grandfathering of non-material updates
  • Option to reject changes (with service impact explanation)
  • Simplified comparison between versions
  • Support channel for questions about changes

10.2 Historical Version Access

We maintain transparency about policy evolution:

Version Archive: A complete history of previous Privacy Shield versions is available at pokies24.io/privacy-archive, allowing you to review how our practices have evolved.

Change Documentation: Each version includes an accompanying change log highlighting significant modifications, additions, and removals.

Timeline Visualization: An interactive timeline shows when and why major privacy practice changes occurred.

Policy Comparison Tool: Our online tool allows side-by-side comparison between any two historical versions.

Contextual Annotations: Historical versions include notes explaining the regulatory or operational context for significant changes.

10.3 Interpretation and Jurisdiction

Understanding the legal foundation of this Privacy Shield:

Governing Framework: This Privacy Shield is governed by the laws of Malta, where Spinwise Gaming Limited is incorporated.

Regulatory Alignment: We design our privacy practices to comply with multiple regulatory frameworks, including GDPR, while maintaining the specific requirements of gaming industry regulations.

Conflict Resolution: Any discrepancies between this Privacy Shield and applicable laws will be resolved in favor of the law offering strongest protection.

Severability Principle: If any provision of this Privacy Shield is found invalid, the remaining provisions remain in full effect.

Questions and Clarification: For interpretive guidance, contact our Data Protection Officer at [email protected].

SECTION 11: CONTACT CHANNELS

11.1 Privacy Team Access

Our dedicated privacy personnel are available through:

General Privacy Questions: [email protected]

Data Protection Officer: [email protected]

Rights Exercise Requests: [email protected]

Urgent Privacy Concerns: +356 2778 0099 (Privacy Hotline)

Postal Correspondence: Data Protection Officer Spinwise Gaming Limited Quantum Business Centre Triq is-Salib tal-Imriehel Birkirkara BKR 3000 Malta

11.2 Complaint Resolution Path

If you have concerns about our privacy practices:

Initial Resolution: Contact our Privacy Team with detailed concerns for prompt investigation and response within 10 business days.

Escalation Process: Unresolved concerns can be escalated to our Data Protection Officer for senior review within 15 additional days.

Regulatory Recourse: You have the right to lodge complaints with supervisory authorities, particularly in your country of residence, workplace, or where the alleged infringement occurred.

Primary Regulator Contact: Office of the Information and Data Protection Commissioner Floor 2, Airways House Triq Il-Kbira Tas-Sliema SLM 1549 Malta

Alternative Dispute Resolution: We participate in GDPR-compliant independent dispute resolution mechanisms for privacy concerns.

11.3 Special Circumstances Contact

For specific privacy situations:

Data Breach Notifications: [email protected] (monitored 24/7)

Sensitive Data Requests: [email protected]

Third-Party Data Concerns: [email protected]

Media and Press Inquiries: [email protected]

Regulatory Investigations: [email protected]

This Privacy Shield was last substantively updated on May 20, 2025. Your continued use of Pokies24.io after this date constitutes acceptance of these terms.

By creating an account, you acknowledge that you have read, understood, and agreed to this Privacy Shield document in its entirety.