Privacy Policy

This Privacy Policy explains how Spinit Casino, operated via the informational website spinit-aussie.com, collects, uses, discloses and protects personal information of players and other visitors. It applies to all users who access or use spinit-aussie.com, any related pages, and any communication channels associated with the brand "Spinit Casino" in the Australian context. This Privacy Policy is effective from 1 January 2026 and replaces any previous versions published on this website.

Who We Are

Observe: The historical operator of the original Spinit Casino brand was Genesis Global Limited, a Malta-registered company whose gambling licences have been cancelled or suspended and whose brands are now closed. The current website, spinit-aussie.com, is an informational resource for Australian users and is not an operator of online gambling services.

Expand: For transparency, we must distinguish between (a) the historical corporate entity behind the former gambling brand and (b) the current entity responsible solely for the informational site. The data shown below about Genesis Global Limited is historical and used for contextual and reference purposes only.

Reflect: We therefore clarify responsibility for personal information in connection with spinit-aussie.com as follows.

Current Website Operator

• Trading name: Spinit Casino (informational site for Australian market)
• Primary domain: https://spinit-aussie.com
• Role: Informational and review-oriented website about Spinit Casino and related gambling topics for Australian users. It does not provide real-money gambling services and is not a licensee under the Interactive Gambling Act 2001 (Cth).

Historical Brand Operator (Context Only)

• Company name: Genesis Global Limited (historical operator; insolvent)
• Legal form: Limited liability company
• Registration number: C65325 (Malta)
• Legal address (historical): 28, GB Buildings, Level 3, Watar Street, Ta' Xbiex, XBX 1301, Malta
• Key licences (historical only, now cancelled/suspended/surrendered):
  • Malta Gaming Authority: MGA/B2C/314/2015 - cancelled effective 16 January 2023 (insolvency)
  • UK Gambling Commission: 45235 (045235-R-323955-013) - suspended December 2022
  • Swedish Gambling Authority (Spelinspektionen): licence surrendered after 2023
• Status: Insolvent; brands, including the original Spinit Casino, are permanently closed.

Note: Any current website claiming to operate "Spinit Casino" and accept Australian players is, to the best of our knowledge, not operated by Genesis Global Limited and may be unregulated or fraudulent. Our site is an independent informational resource only.

Data Protection Contact

• Data protection contact / DPO function: Data Protection Officer - spinit-aussie.com
• Email (primary): [email protected]
• Email (general enquiries): [email protected]
• Additional contacts (non-privacy specific):
  • [email protected] - media enquiries
  • [email protected] - recruitment matters
• Postal contact (historical corporate reference only): 28, GB Buildings, Level 3, Watar Street, Ta' Xbiex, XBX 1301, Malta (Genesis Global Limited)

Regional compliance note: For Australian users, we seek to align our practices with the principles of the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), even though we are an offshore informational service.

What Personal Data We Collect

Observe: We collect personal and technical information when you use spinit-aussie.com, contact us, or interact with our content or advertising. No real-money gambling accounts or bets are processed on this site, but we may refer to historical betting-related information in our content.

Expand: To operate and improve this informational site, we need limited identification data, technical and device information, analytics data, and marketing-related preferences, primarily via forms and cookies.

Reflect: The categories of personal data we may collect and process are:

Identification and Contact Data

• Full name, display name or alias (if you provide it in a contact form or email).
• Email address (e.g., when you email [email protected] or subscribe to newsletters).
• Telephone number (only if you voluntarily provide it; we do not require it by default).
• Country or region, language preference, and time zone (where provided or reasonably inferred).

Technical and Usage Data

• IP address, approximate location (city/region level), and internet service provider.
• Device information: device type, operating system, browser type and version, screen resolution.
• Log data: access times, pages viewed, referring/exit pages, click paths, error logs.
• Interaction data: links clicked, scroll behaviour, time spent on pages, and interaction with banners or forms.

Payment and Financial Data

• spinit-aussie.com does not process deposits, withdrawals, or bets, and does not run player accounts.
• We therefore do not intentionally collect full payment card numbers or bank account details.
• However, historical information about Genesis Global Limited's PCI DSS compliance (for the former real-money platform) may be referenced in our content. Such information is descriptive only and not linked to identifiable individuals.

Behavioural and Preference Data

• Information on pages visited (e.g., bonus guides, game reviews, responsible gambling content).
• Outbound clicks to third-party gambling or affiliate sites (tracked via redirect links or UTMs).
• Marketing preferences: subscription status to newsletters or promotional communications.
• Content interaction: comments, questions or feedback you provide via email or forms.

Cookies and Similar Technologies

• HTTP cookies and HTML5 local storage to remember preferences and measure website performance.
• Analytics cookies (e.g., Google Analytics or equivalent) to understand usage trends.
• Advertising and affiliate tracking cookies to record referral activity and campaign performance.
• Web beacons, pixels and similar tracking identifiers embedded in emails or on pages.

Where required by applicable law, we will request your consent before setting non-essential cookies or similar technologies on your device.

Legal Basis for Processing

Observe: As an offshore informational gambling site with Australian users, we rely on a combination of consent, contractual necessity (or steps prior to entering a contract, e.g., responding to your enquiries), legitimate interests, and legal obligations under applicable data protection and consumer protection frameworks.

Expand: Although Australia is the primary audience, we also align our approach with international standards such as the EU General Data Protection Regulation (GDPR) to facilitate consistent rights and protections, especially for users accessing our content from the EEA or UK.

Reflect: Our main legal bases for processing personal data are:

• Consent
  • For setting non-essential cookies (analytics, advertising, affiliate tracking) where law requires prior consent.
  • For sending you marketing emails or newsletters, where you actively opt in.
  • For processing any optional information you voluntarily include in correspondence (e.g., detailed feedback).
• Performance of a contract or steps prior to entering into a contract
  • To respond to your queries about the site, our content, or historical information about Spinit Casino.
  • To provide you with requested services, such as subscription-based information updates.
• Legitimate interests
  • To operate, maintain and improve spinit-aussie.com and our services in a secure and efficient manner.
  • To measure the performance of our content, affiliate links, and advertising campaigns.
  • To prevent fraud, abuse, or misuse of the website and to protect our legal rights.
  • To keep records needed for business management, audit and dispute-handling purposes.
• Compliance with legal obligations
  • To comply with applicable data protection laws (such as the Privacy Act 1988 (Cth), GDPR where applicable) and consumer law.
  • To respond to lawful requests from regulators, courts, or law enforcement in relevant jurisdictions.
  • To maintain records that may be required under accounting, tax, or corporate laws applicable to our operations.

Where we rely on legitimate interests, we balance our interests against your fundamental rights and freedoms and implement safeguards (e.g., pseudonymisation, opt-out options) to minimise any privacy impact.

Purpose of Processing

Observe: We use the information collected through spinit-aussie.com to operate an informational platform, understand user behaviour, and support compliant affiliate and advertising activities.

Expand: Because we do not manage player accounts or accept bets, our purposes do not include operational gambling account management but are instead focused on content provision and responsible marketing.

Reflect: We process personal data for the following purposes:

• Providing and operating our services
  • To present the website and its content (guides, reviews, responsible gambling information) to you.
  • To respond to enquiries sent to [email protected], [email protected] or other emails.
  • To manage newsletter subscriptions and communications you have requested.
• Improving and developing the service
  • To analyse aggregated usage data and understand which content is most relevant to Australian users.
  • To test new pages, features or layouts and optimise usability and performance.
  • To detect, troubleshoot and fix technical issues (e.g., broken links, loading errors).
• Marketing, affiliation and advertising
  • To display or track advertising and affiliate links to third-party gambling operators or comparison sites.
  • To measure the effectiveness of marketing campaigns and affiliate partnerships.
  • To send promotional or informational communications where you have opted in.
• Analytics and statistics
  • To compile aggregate statistics on site traffic, referral sources, and user journeys.
  • To understand trends in Australian and international traffic to our Spinit Casino pages.
• Fraud prevention and security
  • To protect the website, our infrastructure and users from automated abuse, spam, scraping, and security incidents.
  • To investigate and respond to suspected misuse, violations of terms, or unlawful activity.
• Legal and regulatory compliance
  • To comply with applicable data protection, consumer and communications laws.
  • To cooperate with relevant regulators such as the Australian Communications and Media Authority (ACMA), the Malta Gaming Authority (MGA), or others where necessary.

Disclosure & Sharing

Observe: Personal data collected via spinit-aussie.com may, in limited circumstances, be shared with carefully selected third parties.

Expand: Given the cross-border nature of online services, these parties may be located in various jurisdictions, and we implement contractual and technical safeguards to protect your information.

Reflect: We may disclose personal data as follows:

Service Providers and Technical Partners

• Website hosting providers and content delivery networks (CDNs).
• Analytics providers (e.g., web analytics tools) to help us understand traffic and usage.
• Email marketing platforms for sending newsletters or service communications.
• IT security and maintenance providers who support the stability and safety of our systems.

Payment and Commercial Partners

• Because spinit-aussie.com does not process player payments, we generally do not share your data with payment processors for transactional purposes.
• In the event of any commercial arrangement involving paid services (for example, if we introduce premium information products in future), relevant payment service providers may receive necessary billing-related data.

Affiliate, Advertising and Marketing Partners

• Affiliate networks and gambling operators for tracking referrals via cookies, pixels and tracking links.
• Advertising networks and technology providers that serve, measure, or optimise advertising on or linked from our site.
• Such sharing typically involves pseudonymised identifiers, device information and browsing data, rather than directly identifiable data like your full name.
• Where required, we will seek your consent for such tracking and will provide opt-out mechanisms.

Regulators, Authorities and Legal Recipients

• Regulatory bodies, enforcement agencies or courts in relevant jurisdictions (e.g., ACMA in Australia, MGA in Malta, UKGC in the UK), where we are legally required or where disclosure is necessary to assert or defend legal claims.
• Professional advisers (lawyers, auditors) subject to confidentiality obligations, where necessary to protect our rights or comply with law.

Corporate Transactions

• In connection with any merger, acquisition, restructuring, sale of assets, or similar transaction involving the informational site or its owner, your data may be transferred to the acquiring entity or its advisers, subject to appropriate confidentiality and data protection safeguards.

We do not sell your personal data as a standalone asset. Any data sharing with affiliates or advertising partners is conducted under contractual terms that limit use to specified purposes and impose security obligations.

International Transfers

Observe: spinit-aussie.com serves users in Australia but relies on infrastructure and partners that may be located in multiple countries and regions, including the European Union, the United Kingdom, and other jurisdictions.

Expand: This can involve transferring personal data outside your country of residence, including to countries which may have different data protection laws.

Reflect: Where such transfers occur, we implement appropriate safeguards to protect your information, such as:

• Standard Contractual Clauses (SCCs)
  • For transfers from the EEA, UK or Switzerland to countries that do not provide an adequate level of protection, we rely on the European Commission's or UK-approved standard contractual clauses, where applicable.
• Contractual and organisational safeguards
  • Data processing agreements (DPAs) with service providers that define security duties, confidentiality obligations and restrictions on further transfers.
  • Technical measures such as encryption in transit and at rest to reduce risk in the event of unauthorised access.
• Data minimisation and pseudonymisation
  • Where reasonably possible, we transfer only the minimum data required and use pseudonymous identifiers rather than directly identifiable data.

By using spinit-aussie.com, you acknowledge that your data may be processed in and transferred to countries outside your jurisdiction, subject to the safeguards described in this Privacy Policy.

Data Retention

Observe: To comply with legal obligations and operate our services, we retain personal data for varying periods depending on the category and purpose of processing.

Expand: Retention must balance regulatory record-keeping requirements with the principle of storage limitation under data protection laws (including the Australian Privacy Principles and, by alignment, GDPR).

Reflect: We apply the following general retention rules:

• Contact and communication data
  • Emails, contact form submissions and correspondence: usually retained for up to 5 years from the date of the last interaction, unless a longer period is required for dispute resolution or legal obligations.
• Newsletter and marketing data
  • Subscription records and marketing preferences are retained for as long as you remain subscribed and for up to 2 years after you unsubscribe, to demonstrate consent history and manage suppression lists.
• Technical and analytics data
  • Server logs, security logs and raw analytics data: typically retained for 12 - 24 months, unless needed longer to investigate ongoing security incidents or persistent abuse.
• Affiliate and advertising tracking data
  • Cookies and tracking identifiers: retained in accordance with their specific lifespan (commonly 30 days to 24 months) and applicable legal requirements or your consent/opt-out settings.
• Legal, audit and dispute records
  • Data necessary for legal claims, regulatory investigations or audits may be kept until the relevant limitation period expires or until the matter is fully resolved.

When data is no longer needed for the purposes described, we either delete it securely, anonymise it so it can no longer be linked to an individual, or aggregate it for statistical analysis. If you request deletion, we will also consider whether we are required or permitted to retain certain information under applicable law.

Your Rights

Observe: Users of spinit-aussie.com have rights in relation to their personal data. While the primary audience is Australian, we align with GDPR standards and, where relevant, other international frameworks.

Expand: The rights described here generally reflect GDPR-style protections, which we voluntarily extend where technically feasible, without limiting any rights you may have under Australian law or, for other users, under their local laws.

Reflect: Subject to applicable law and certain limitations, you may have the following rights:

• Right of access
  • You may request confirmation of whether we process your personal data and obtain a copy of such data, together with information on how we use it.
• Right to rectification
  • You may request correction of inaccurate data and completion of incomplete data.
• Right to erasure ("right to be forgotten")
  • You may request deletion of your personal data where it is no longer necessary, you withdraw consent (where processing was based on consent), you validly object to processing, or we are required by law to erase it.
• Right to restriction of processing
  • You may request that we restrict processing of your data in certain circumstances (e.g., while we verify its accuracy or assess an objection).
• Right to object
  • You may object to processing based on legitimate interests, including profiling, on grounds relating to your particular situation. We will stop processing unless we demonstrate compelling legitimate grounds.
  • You may object at any time to the use of your data for direct marketing and related profiling; we will comply promptly.
• Right to data portability
  • Where processing is based on consent or a contract and carried out by automated means, you may request that we provide your data in a structured, commonly used and machine-readable format or transmit it to another controller where technically feasible.
• Right to withdraw consent
  • Where we rely on your consent, you may withdraw it at any time. This does not affect the lawfulness of processing prior to withdrawal but may affect our ability to continue certain services (e.g., newsletters).

How to Exercise Your Rights

1. Submit a request
   • Send an email to [email protected] or [email protected] with a clear description of your request (e.g., access, correction, deletion).
2. Verification
   • We may ask you for additional information to verify your identity and protect against unauthorised access to your data.
3. Response timeframe
   • We aim to respond within 30 days of receiving a valid request. If your request is complex or we receive multiple requests, we may extend this period by a further 30 days, and we will inform you of the extension and reasons.
4. Fees
   • We generally handle requests free of charge. However, where a request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act, as permitted by law.

Note: Some rights may not be fully applicable in all jurisdictions or may be subject to exceptions (for example, where we must retain data for legal reasons). We will explain any such limitations in our response.

Cookies & Tracking Technologies

Observe: spinit-aussie.com uses cookies and similar technologies to operate the site, remember your preferences, perform analytics, and support advertising and affiliate activities.

Expand: Cookies are small text files stored on your device; they may be session-based (deleted when you close your browser) or persistent (stored for a defined period). Third-party cookies may be set by partners providing services on our site.

Reflect: The main categories of cookies and tracking technologies we use are:

Types of Cookies

• Strictly necessary / functional cookies
  • Ensure core site functionality (e.g., page navigation, basic preferences, load balancing).
  • These cookies are usually set in response to your actions (such as setting privacy preferences). They cannot be switched off in our systems, and consent may not be required under some laws.
• Analytics and performance cookies
  • Collect aggregated information about how visitors use the site (pages visited, time spent, errors encountered).
  • Used to improve user experience and site performance.
• Advertising and affiliate cookies
  • Track clicks on ads and outbound affiliate links to gambling operators or comparison sites.
  • Help us understand campaign performance and calculate affiliate commissions.
  • May be used by third parties to build a profile of your interests and show relevant ads on other sites.
• Social media and third-party content cookies
  • Set by social media platforms or content providers whose services we embed on our site.
  • Enable content sharing and may be used by those third parties for their own purposes.

Managing Cookies

• You can manage or disable cookies through your browser settings (e.g., blocking all cookies, restricting third-party cookies, or receiving alerts before a cookie is stored).
• You can delete existing cookies from your browser at any time.
• Where we provide an internal cookie or privacy preference panel, you may adjust your cookie choices directly on the site (e.g., opt out of analytics or advertising cookies).
• Disabling certain cookies may impact site functionality or the availability of some features.

For more detailed information on specific cookies in use at any given time, please refer to any cookie banner or settings interface available on spinit-aussie.com.

Data Security

Observe: Protecting your personal data is a high priority. We implement technical and organisational measures designed to provide a level of security appropriate to the risk.

Expand: Security measures apply to data in transit and at rest, access control, staff awareness, and incident response readiness. While no system is completely risk-free, we strive to follow recognised industry practices.

Reflect: Our security measures include, where appropriate:

• Encryption
  • Use of TLS 1.2 or higher for encrypting data transmitted between your browser and our servers.
  • Encryption of sensitive data at rest, where technically feasible and appropriate.
• Access controls and authentication
  • Role-based access controls, ensuring that only authorised personnel and trusted service providers can access personal data.
  • Use of strong authentication methods and, where feasible, multi-factor authentication for administrative systems.
• Infrastructure and application security
  • Regular application of security patches and updates to systems and software.
  • Use of firewalls, intrusion detection or prevention systems, and other safeguards.
• Monitoring, audits and testing
  • Logging and monitoring of system activity to detect unusual or suspicious behaviour.
  • Periodic internal reviews and assessments of security controls, and, where applicable, third-party audits.
• Staff training and confidentiality
  • Confidentiality obligations for staff and contractors with access to personal data.
  • Training and awareness measures on data protection and security responsibilities.
• Incident response
  • Procedures to identify, assess and respond to potential data breaches, including notification to affected individuals and relevant authorities where required by law.

Historically, the former Spinit Casino gambling platform operated under PCI DSS standards for card data security. While the current spinit-aussie.com informational site does not process card payments, we maintain comparable diligence with respect to the types of data we do process.

Complaints & Contacts

Observe: Users should have clear channels to raise privacy-related questions or complaints and to escalate unresolved issues to supervisory authorities.

Expand: As an offshore informational site with a focus on Australian users, we consider both the availability of our internal complaint mechanism and the roles of relevant regulators in Australia and, where applicable, the EU/EEA or UK.

Reflect: If you have concerns or wish to lodge a complaint, you may proceed as follows:

Contacting Us

• Email (primary for privacy matters): [email protected]
• Email (alternative): [email protected]
• Press-related queries: [email protected]
• HR-related queries: [email protected]

Internal Complaint Procedure

1. Submit your complaint
   • Send us a written explanation of your concern, specifying the nature of the issue, the relevant timeframe, and any supporting information or documentation you wish to provide.
2. Acknowledgement
   • We aim to acknowledge receipt of your complaint within 5 business days.
3. Investigation
   • We will investigate your complaint, which may include reviewing logs, communications and applicable legal obligations.
4. Response
   • We aim to provide a substantive response within 30 days. If more time is required due to complexity, we will inform you of the extension and expected timeline.
5. Resolution or further steps
   • We will outline the outcome, any remedial measures, and your options if you remain dissatisfied.

Escalation to Supervisory Authorities

Depending on your location and circumstances, you may also have the right to lodge a complaint with a data protection or privacy regulator.

• Australia
  • Office of the Australian Information Commissioner (OAIC)
  • Website: https://www.oaic.gov.au
• European Union / EEA
  • If you are located in the EU/EEA, you may contact your local data protection authority. A list is available via the European Data Protection Board (EDPB): https://edpb.europa.eu/about-edpb/about-edpb/members_en.
• United Kingdom
  • Information Commissioner's Office (ICO)
  • Website: https://ico.org.uk
• Malta
  • Office of the Information and Data Protection Commissioner (IDPC)
  • Website: https://idpc.org.mt

For historical player complaints regarding Genesis Global Limited under the Malta Gaming Authority (MGA), a legacy contact point is available at https://mga.org.mt/player-hub/lodge-a-complaint/. However, many such complaints may now be time-barred or outside the MGA's remit due to the operator's insolvency.

Updates

Observe: Laws, regulatory expectations, and our services may change over time, requiring us to update this Privacy Policy.

Expand: We must give users clear notice of material changes, maintain version control, and allow users to make informed choices, including the option to discontinue use if they do not agree with changes.

Reflect: Our update and notification practices are:

• Version and date
  • This Privacy Policy is identified as: Version 1.0 - Last updated: January 2026.
• Non-material changes
  • Minor updates (e.g., clarifications, typographical corrections, changes to contact details) may be made without prior notice. The "Last updated" date will always reflect the most recent change.
• Material changes
  • For significant changes that materially affect how we process personal data (e.g., new categories of data, new purposes, or major changes in sharing practices), we will provide more prominent notice, which may include:
    • Announcements or banners on the spinit-aussie.com website;
    • Email notifications to subscribed users, where appropriate;
    • Alerts in any user account or preference centre if such functionality is available.
  • Where feasible, we will provide at least 30 days' advance notice before material changes take effect, unless immediate implementation is required by law or necessary for security reasons.
• User options
  • If you do not agree with the updated Privacy Policy, you may discontinue use of spinit-aussie.com and, where applicable, withdraw consent for specific processing (such as marketing communications or cookies).
  • You may also exercise your rights (e.g., access, deletion) in response to any changes in how your data is processed.

We encourage you to review this Privacy Policy periodically to stay informed about how Spinit Casino, via spinit-aussie.com, protects your privacy and handles your personal data.