Privacy Policy

SpinSaga Inc. (“SpinSaga,” “Company,” “we,” “us,” or “our”) is a brand operated by CYLON TECHSOFT PRIVATE LIMITED that values and safeguards the privacy of visitors to SpinSaga.com (“Site”) and users of the SpinSaga mobile application available on iOS and Android (the “App,” together with the Site, the “Services”). We have a strict policy in place to protect the privacy of our Visitors and Players (as defined in this policy). This Privacy Policy outlines the types of information we may collect from you and how we collect, use, maintain, protect, and disclose such information. The Privacy Policy also covers certain rights that you may have over information we collect from you. Terms used in this Privacy Policy that are not defined have the same meaning as defined in the SpinSaga Terms and Conditions (“Terms”).

By accessing or using the Services, you are agreeing to this Privacy Policy. If you do not agree with our policies and practices, your only option is to not use the Services. As stated below, this policy may change periodically. Please check the policy for updates and continued use of the Services after changes are made will be considered acceptance of those changes.

1. Policy Overview

Our commitment to protecting the privacy of individuals who visit our Site (“Visitors”) and users who have registered for an account or downloaded the App (“Players”) is outlined in this Policy. This policy applies to information that is automatically collected via the Services or that is provided to us by Visitors or Players.

However, this Privacy Policy does not apply to:

• Offline Information. Information collected by us offline or through any other means, including on any other website operated by SpinSaga or any third party (including our affiliates and subsidiaries) is not subject to this Privacy Policy.
• Third Parties. We are not responsible for the privacy policies or other practices employed by websites linked to, or from, our Site or App, nor the information or content contained therein. We encourage you to read the privacy statements of any linked third party.

This Privacy Policy is a legally binding contract between the Operator and anyone who accesses or uses the Services. By using the Services, you are agreeing to be bound by the terms of this Privacy Policy, that may be amended from time to time, and to the collection, storage, use, and protection of personal information as described herein. If you do not wish to be bound by this Privacy Policy, please discontinue use of the Services immediately.

SpinSaga reserves the right to amend this Privacy Policy and the Terms and Conditions from time to time at our sole discretion. We will notify you of any material change by posting the revised Privacy Policy on the Services. Any changes to the Privacy Policy will be effective immediately upon notification. For any non-material change that does not require notification, your continued use and access of the Services subsequent to such change or amendment will be deemed as acceptance of such change or amendment. We encourage you to visit this Privacy Policy from time to time to ensure that you are aware of the current version and any changes that we may make.

2. Information Collected

At SpinSaga, we collect a variety of information about our Visitors and Players, including:

• Personal Data, which may include your name, email address, phone number or any other identifier that may be used to contact you online or offline;
• Non-Personal Data, which may be information about you but does not identify you individually;
• Usage details, information about your internet connection and the equipment you use to access our Services.
• Location of you or your device at the time of accessing certain services or sections of the site or app.

We collect this information from you directly when you provide it to us, automatically as you navigate through the Services, or from third parties such as our business partners.

Information That You Provide Directly to Us:

• When you register to use our Services or request certain materials, we may require you to provide Personal Data, such as your name, email address, phone number, driver's license, birth date, gender, and unique identifiers, like a username or password. We may also receive Personal Data from records and copies of your correspondence, dialog boxes or chats, your responses to surveys or feedback requests, or details of transactions you conduct through our Services.
• Additionally, we may obtain Personal Data if you choose to publish or display information (referred to as “User Contributions”) on public areas of our Services or transmit it to other Players or third parties. Your User Contributions are posted and transmitted to others at your own risk, and we cannot control the actions of other Players with whom you choose to share your User Contributions. As a result, we cannot guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatically Collected Information Through Your Use of the Services:

• While you use our Services, we may gather certain demographic data and information about your interaction history, devices, IP address, operating system, browser type, browsing behavior and patterns, using automatic data collection technologies. This information is statistical in nature and does not include personal information, but we may retain it or associate it with personal information we gather through other methods. We use this information to enhance our Services and provide a better and more customized service. It allows us to estimate our audience size and usage patterns, store information about your preferences, and identify you when you revisit our Services.
• The automatic data collection technologies we use may include:
  • Cookies (or browser cookies). SpinSaga uses cookies on its Services. A cookie is a small file placed on your device's hard drive or internal storage. We use cookies to track and report on your activity on the Site or App. Through cookies, we can gather data that we use to improve the Services, keep track of return visits to our website, collect and report on aggregate statistical data, authenticate your login credentials, or manage multiple instances of the Site in a single browser. We may also collect other data, such as the page or site that referred you to the Site, the date and time of your visit, and your current IP address. You can reject browser cookies by enabling the appropriate setting in your browser. However, if you do so, you may not be able to access certain parts of our Site, or the Services and functionality may be limited. Unless you have modified your browser's settings to refuse cookies, our system will issue cookies when you direct your browser to our Site.
  • Our Site and e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to count users who have visited those pages or opened an email and for other related website statistics. Occasionally, we connect personal information to information gathered in our log files to improve our Site and Services. If we do so, we would treat the combined information in accordance with this Privacy Policy. Log files that we collect may include IP addresses, browser type, domain names, access times, and physical location.
  • Heat mapping services are used on our Site to display the areas of a page where Players most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of Player behavior. Some of these services may record sessions and make them available for later visual playback.
  • Our Services collect real-time information about the location of your device. Disabling location data or falsifying your location will impair the functions of Services, including prohibiting you from entering contests, depositing and withdrawing funds.

We do not collect personal information automatically, but we may link this information to personal information about you that we collect from other sources you provide to us.

3. How We Use Your Data

SpinSaga may use aggregated (anonymized) information about its users and non-personal information without restriction. We will limit the collection of your Personal Data to the extent necessary for the purposes identified by SpinSaga. Unless you consent or we are required by law, we will only use the Personal Data for the purposes for which it was collected. If SpinSaga processes your Personal Data for another purpose later on, SpinSaga will seek your further legal permission or consent, unless the other purpose is compatible with the original purpose. We will retain your Personal Data only for as long as necessary to serve those purposes and will also retain and use your Personal Data as necessary to comply with our legal obligations and resolve disputes.

We use information, including Personal Data, about you for various purposes, including:

• Collecting or disbursing payment for transactions made through the Services;
• Generally enabling you to use our Services;
• Providing you with information, products, or services you request;
• Customizing and personalizing the content we deliver to you;
• Providing customer service and support;
• Sending you administrative messages about the Services;
• Carrying out our obligations and enforcing our rights arising from any contracts entered into between you and us, including billing and collection;
• Notifying you of changes to our Services or any products or services we offer or provide through it;
• Monitoring and analyzing trends, usage, and activities in connection with the Services;
• Investigating and preventing fraudulent transactions, unauthorized access to the Services, violations of the Terms, and other illegal activities;
• Sharing testimonials or reviews that you may have posted to the Services or other SpinSaga owned social media pages;
• For any other purpose with your consent or as permitted by our Terms and Conditions and this Agreement;
• Contacting you about our own and third-parties' goods and services that may be of interest to you.

If you do not want us to use your information for contacting you related to goods or services of interest or promotional purposes, please adjust your user preferences in your account profile or by following the unsubscribe instructions included in our marketing communications.

4. Sharing of Your Information

We may share information about our Visitors and Players that is aggregated and does not identify individuals, including anonymized contest data, without restriction. We may share Personal Data that we collect or that you provide:

• With other SpinSaga Players to share your public profile.
• With our subsidiaries and affiliates.
• With third-party service providers for account authentication or management.
• With contractors, service providers, and other third parties we use to support our business, who are obligated to keep personal information confidential and use it only for the purposes for which we disclose it to them. These third parties may include payment processors and analytics contractors.
• With a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SpinSaga's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by SpinSaga about our Visitors and Players is among the assets transferred. If we make such a change, we will notify you by prominently displaying a notice on our Services or by email to the primary address associated with your account. Any successor in interest to this Privacy Policy will be bound by the Privacy Policy at the time of transfer.
• To comply with any court order, law, or legal process, including to respond to any government or legal request.
• To enforce or apply our Terms and other agreements, including for billing and collection purposes.
• We may disclose your personal information if we believe it is necessary or appropriate to protect the rights, property, or safety of SpinSaga, our Players, or others. This may include sharing information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

5. Data Security

To protect your Personal Data from unauthorized access, use, alteration, or disclosure, we have implemented industry-standard technical and organizational measures. These measures are designed to provide an appropriate level of security based on the risk associated with processing your Personal Data. All information that you provide to us is stored on secure servers behind firewalls.

The security of your information also depends on you. You are responsible for keeping your username and password confidential. Please do not share your password with anyone. When sharing information in public areas of the Services such as message boards or company profile pages, please exercise caution as any Player or Visitor of the Services may view this information depending on where it is posted. SpinSaga staff do not have access to player passwords. SpinSaga support staff or personnel will never ask you for your password or part of your password to identify you or to assist you with access to your account. Never disclose your password to anyone via phone, messenger, SMS, WhatsApp or any other communication method.

Although we take steps to protect your personal information, we cannot guarantee the complete security of information transmitted through the internet. Any transmission of Personal Data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Services.

6. Choices You Have for Your Personal Data

To review or modify your personal information, you can access your account profile page. You may also request access to, correction or deletion of any personal information by sending an email to us. However, we may decline a request to change information if we believe it would violate any legal requirement or cause the information to be incorrect. If you delete User Contributions from the Services, copies of your contributions may still be available on cached or archived pages or may have been copied or stored by other Players or Visitors. Database entries of User Contributions will remain in place for record keeping and legal purposes, although will not be publicly accessible.

You have the option to allow or block the App from collecting real-time information about your device's location through your device's privacy settings. Blocking location information may restrict access to some parts of the Services or cause them to malfunction.

You can adjust your browser settings to refuse all or some cookies, or to be alerted when cookies are sent. Disabling or blocking cookies or other tracking technologies may restrict access to some parts of the Services or cause them to malfunction.

SpinSaga only sends permission-based email and provides Players with the option to opt-out or change preferences through a link in all non-transactional email messages. Some communications, such as important account notifications and billing information, are considered transactional and are necessary for all SpinSaga Players. To unsubscribe from transactional communications, you must cancel your SpinSaga account.

At this time, SpinSaga does not respond to "Do Not Track" signals or other similar mechanisms. To learn more about "Do Not Track," you can visit www.allaboutdnt.com

7. Changes to the Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time and without prior notice. Any changes to this Privacy Policy will be posted on this page with a notice that the Privacy Policy has been updated on the Site home page or on the App. If we make any material changes to how we treat your Personal Data, we will notify you by email to the primary email address specified in your account, through a prominent notice on the Site home page, or on the App. The revised Privacy Policy will be effective immediately upon posting, and the date of the last revision will be identified at the top of this page. You are responsible for ensuring that we have an up-to-date, active, and deliverable email address for you and for periodically reviewing this Privacy Policy to be informed of any changes. Your continued use of our Services after the posting of any amendment, modification, or change to this Privacy Policy constitutes your acceptance of the amendments to this Privacy Policy. If you do not accept the terms of this Privacy Policy or any modified version of this Privacy Policy, you may choose to discontinue the use of the Services.

8. Geolocation Data

If you use location-based services, we may collect, process, maintain, and use your location data to provide and enhance such services. By using these services, you consent to this data usage. If you wish to withdraw your consent, you may turn off location settings or inform us in writing. However, please note that if you do so, your access to and use of the Services, the Online Software, and App Software may be restricted, blocked, or terminated.

9. Further Information

For more information, please contact support@SpinSaga.com