Privacy Policy

Data Protection and Privacy Rights

Last Updated: January 2025

1. Overview

Winspinnijat AS ("we," "our," or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, and protect your information when you use our social casino entertainment platform.

GDPR Compliance

As Norway is part of the European Economic Area (EEA), the General Data Protection Regulation (GDPR) applies to our processing of your personal data. This policy outlines your rights and our obligations under GDPR.

2. Data Controller

Data Controller: Winspinnijat AS

Address: Postboks 105, 0101 Oslo, Norway

Contact: privacy@winspinnijat.com

3. Information We Collect

Personal Information

  • Contact Information: Email address, name (when provided through contact forms)
  • Account Information: Username, age verification status
  • Communication Records: Support inquiries and correspondence

Technical Information

  • Device Information: Browser type, device type, operating system
  • Usage Data: Pages visited, time spent, interactions with games
  • Cookies and Tracking: As described in our Cookie Policy

Gaming Data

  • Game Progress: Virtual credits, achievements, game statistics
  • Preferences: Game settings, display preferences
  • Platform Interaction: Feature usage, time spent in different sections

We process your personal data based on the following legal grounds:

  • Consent: For analytics, marketing cookies, and optional features
  • Contractual Necessity: To provide our social casino services
  • Legitimate Interest: For platform security, fraud prevention, and service improvement
  • Legal Obligation: To comply with Norwegian regulations and age verification requirements

5. How We Use Your Information

Service Provision

  • Provide and maintain our social casino platform
  • Process your requests and provide customer support
  • Verify age and geographic eligibility
  • Save your game progress and preferences

Communication

  • Respond to your inquiries and support requests
  • Send important platform updates and policy changes
  • Provide information about new features (with consent)

Analytics and Improvement

  • Analyze platform usage to improve user experience
  • Monitor platform performance and security
  • Conduct research on gaming preferences and behavior

Legal Compliance

  • Comply with Norwegian gambling and consumer protection regulations
  • Maintain records for regulatory reporting
  • Prevent fraud and ensure platform security

6. Data Sharing and Disclosure

We do not sell your personal data. We may share information in the following circumstances:

Service Providers

  • Analytics services (with your consent)
  • Cloud hosting and security services
  • Customer support tools

Legal Requirements

  • Compliance with court orders or legal processes
  • Reporting to Norwegian regulatory authorities when required
  • Protection of our rights and prevention of fraud

Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction, subject to the same privacy protections.

7. Data Retention

  • Account Data: Retained while your account is active and for 2 years after account closure
  • Transaction Records: Retained for 5 years for regulatory compliance
  • Analytics Data: Retained for 2 years in aggregated, anonymized form
  • Support Records: Retained for 3 years after the last interaction
  • Age Verification: Verification records retained for regulatory compliance periods

8. Your Rights Under GDPR

As a data subject, you have the following rights:

Access and Information

  • Right of Access: Request a copy of the personal data we hold about you
  • Right to Information: Understand how and why we process your data

Data Management

  • Right to Rectification: Correct inaccurate or incomplete personal data
  • Right to Erasure: Request deletion of your personal data ("right to be forgotten")
  • Right to Restriction: Limit how we process your data
  • Right to Data Portability: Receive your data in a structured, machine-readable format

Processing Rights

  • Right to Object: Object to processing based on legitimate interests
  • Right to Withdraw Consent: Withdraw consent for voluntary processing activities
  • Right to Complain: File a complaint with the Norwegian Data Protection Authority (Datatilsynet)

Exercising Your Rights

To exercise any of these rights, contact us at privacy@winspinnijat.com. We will respond within 30 days of receiving your request.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience. Our use of cookies is categorized as follows:

Cookie Categories

  • Strictly Necessary: Essential for website functionality (always active)
  • Analytics: Help us understand website usage (requires consent)
  • Marketing: Used for advertising and personalization (requires consent)

For detailed information about our cookie practices, please review our Cookie Policy.

Managing Cookie Preferences

You can manage your cookie preferences at any time by:

  • Using our cookie consent manager (available in the footer)
  • Adjusting your browser settings
  • Contacting us for assistance

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

  • Encryption: Data transmission and storage are encrypted
  • Access Controls: Limited access to personal data on a need-to-know basis
  • Security Monitoring: Regular monitoring for security threats and vulnerabilities
  • Staff Training: Regular privacy and security training for our team
  • Incident Response: Procedures for responding to potential data breaches

11. International Data Transfers

Your personal data is primarily processed within the EEA. If we transfer data outside the EEA, we ensure adequate protection through:

  • European Commission adequacy decisions
  • Standard Contractual Clauses
  • Appropriate safeguards as required by GDPR

12. Protection of Minors

  • Age Verification: We require users to be at least 18 years old
  • No Targeting: We do not knowingly collect data from individuals under 18
  • Parental Rights: If you believe we have collected data from a minor, please contact us immediately
  • Account Removal: We will promptly delete accounts and data belonging to users under 18

13. Policy Changes

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will:

  • Notify you of significant changes via email or platform notification
  • Update the "Last Updated" date at the top of this policy
  • Provide a summary of key changes when applicable
  • Obtain fresh consent for material changes affecting your rights

14. Contact Information

For privacy-related questions, requests, or concerns:

Regulatory Authority

You have the right to lodge a complaint with the Norwegian Data Protection Authority: