We are committed to protecting your personal data with the highest standard of care. This policy explains exactly what we collect, why we collect it, and how we keep it secure.
Six core principles that govern how spin39 handles every piece of personal information you share with us.
We collect only the data that is strictly necessary for providing our services, complying with legal obligations, and improving your experience. We never collect data speculatively or beyond our stated purposes.
All data transmitted between your device and spin39 servers is protected by industry-standard 256-bit SSL encryption. Data at rest is encrypted using AES-256, and our infrastructure undergoes regular third-party security audits.
Your personal data is never sold to third parties. We share information only with carefully vetted service providers who are contractually bound to protect it, or when required by law or our licensing authorities.
Data collected for one purpose is not reused for incompatible purposes without your explicit consent. We maintain clear internal boundaries on who can access which categories of player data.
You have the right to access, correct, port, and request deletion of your personal data. All such requests are handled within 30 days of receipt, in accordance with applicable data protection standards.
We do not retain your personal data beyond what is necessary. Retention schedules are defined by legal requirements and operational needs, after which data is securely deleted or anonymized.
Important Notice: This Privacy Policy ("Policy") describes how spin39 ("Company," "we," "us," or "our") collects, processes, stores, and protects the personal information of users ("Player," "User," "you," or "your") who access and use the spin39 platform at https://spin39.cam. By registering an account or using our services, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.
If you are not comfortable with any aspect of this Policy, please discontinue use of our services immediately and contact our support team to close your account and request data deletion.
For the purposes of this Privacy Policy, the following terms have the meanings set out below:
spin39 collects several categories of personal information depending on how you interact with our platform. The table below summarizes the categories, specific data points, and the primary reason each is collected.
| Category | Specific Data Points | Primary Purpose |
|---|---|---|
| Identity Data | Full legal name, date of birth, national ID (KTP) number, passport number, gender | Account registration, KYC verification, age confirmation |
| Contact Data | Email address, mobile phone number, residential address (city, province, postal code) | Account communication, support, transaction notifications |
| Financial Data | Bank account name, bank account number, bank name (BCA, BRI, BNI, Mandiri, etc.), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja) | Deposit processing, withdrawal disbursement, fraud prevention |
| Identity Documents | Scanned or photographed copies of government-issued ID, selfie photographs for liveness verification | KYC compliance, anti-fraud, regulatory requirements |
| Technical Data | IP address, device type, browser type and version, operating system, session timestamps, login history | Security monitoring, fraud detection, service optimization |
| Usage Data | Pages visited, game sessions played, bet history, deposit and withdrawal history, bonus usage, support interactions | Service improvement, personalization, responsible gaming monitoring |
| Communication Data | Live chat transcripts, email correspondence, WhatsApp and Telegram message logs with our support team | Support quality assurance, dispute resolution, compliance records |
We collect data directly from you when you register an account, complete the KYC verification process, make a deposit or withdrawal, contact our customer support team, participate in promotions or surveys, or update your account profile settings.
When you access the spin39 platform, our systems automatically collect certain technical and usage data via cookies, server logs, and similar tracking technologies. This includes your IP address, device identifiers, browser information, and detailed records of your interactions with our platform. This automated collection occurs whether or not you are logged in to your account.
In certain circumstances, we may receive information about you from third-party sources, including: identity verification partners who assist with KYC processing, payment processors and banking partners such as BCA, BRI, BNI, Mandiri, CIMB Niaga, and OCBC NISP, fraud detection and anti-money laundering service providers, and publicly available records where permitted by applicable law. Data received from third-party sources is handled with the same level of care as data collected directly from you.
spin39 processes your personal data for the following specific purposes:
Every instance of personal data processing at spin39 is grounded in one of the following legal bases:
spin39 engages carefully selected third-party service providers to assist in delivering our platform and services. These providers act as Data Processors under written contracts that strictly limit their use of your data to the agreed purpose. Categories of service providers include identity verification and KYC partners, payment gateway operators, cloud infrastructure and hosting providers, cybersecurity and fraud detection firms, and customer support software vendors.
To process your deposits and withdrawals, we share the minimum necessary financial and identity information with your designated payment provider. This may include Indonesian bank partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja). These institutions operate under their own privacy policies and regulatory obligations.
We may disclose your personal data to law enforcement agencies, regulatory authorities, courts, or government bodies if we are legally required to do so, or if we determine in good faith that disclosure is necessary to protect the rights, property, or safety of spin39, our players, or the public. We will notify you of such disclosures wherever permitted by law.
spin39 does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. Your data is your data — we treat it as such.
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements. The following retention periods apply as general guidelines:
Upon expiration of the applicable retention period, personal data is securely deleted or irreversibly anonymized using industry-accepted methods.
spin39 implements a comprehensive suite of technical security measures to protect your personal data against unauthorized access, loss, alteration, and destruction. These include 256-bit SSL/TLS encryption for all data in transit, AES-256 encryption for data at rest, multi-factor authentication requirements for internal system access, regular penetration testing and vulnerability assessments conducted by independent third-party firms, and real-time intrusion detection and monitoring systems.
Access to personal data within spin39 is governed by a strict role-based access control (RBAC) policy. Only personnel who require access to specific data categories to perform their job functions are granted that access. All staff members with data access undergo regular privacy and security training. Our data handling procedures are reviewed at least annually and updated in response to emerging threats and regulatory developments.
In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, spin39 will notify affected users without undue delay, and no later than 72 hours after becoming aware of the breach where feasible. Notifications will be sent via the email address registered to your account and will describe the nature of the breach, the data involved, and the steps we are taking to address it.
As a user of spin39, you have the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected]. We will respond within 30 days of receiving your request.
Request a copy of all personal data we hold about you, along with information about how it is processed.
Request correction of any inaccurate or incomplete personal data we hold about you.
Request deletion of your personal data where we no longer have a legal basis to retain it, subject to our regulatory obligations.
Request that we restrict processing of your personal data in certain circumstances, such as while a dispute is being resolved.
Request a structured, machine-readable copy of your personal data to transfer to another service provider.
Object to processing of your personal data based on legitimate interests, including objecting to direct marketing communications at any time.
Please note that certain rights may be limited where we are required by law to retain or process your data — for example, to meet AML and KYC regulatory obligations. We will always explain the basis for any limitation clearly when responding to your request.
Cookies are small text files placed on your device when you visit the spin39 website. They allow our platform to recognize your device, remember your preferences, maintain your logged-in session, and collect analytical data about how you use our services.
You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the spin39 platform, including your ability to stay logged in or access certain features. Strictly necessary and security cookies cannot be disabled without preventing you from using the platform altogether.
spin39 is strictly an adults-only platform. You must be at least 21 years of age to register an account or use any of our services. We do not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory component of our KYC process, and all players are required to provide proof of age before withdrawal privileges are activated.
If we become aware that a person under the age of 21 has registered an account or provided us with personal data, we will immediately close the account, delete all associated data to the extent permitted by our legal obligations, and — where appropriate — report the matter to relevant authorities. Parents and guardians are strongly encouraged to use parental control software to prevent minors from accessing online gambling websites.
spin39 reserves the right to update or modify this Privacy Policy at any time. When material changes are made, we will notify you via the email address registered to your account at least 14 days before the changes take effect. The updated Policy will also be published on this page with a revised "Last Updated" date at the top.
Your continued use of spin39 services after the effective date of any policy update constitutes your acceptance of the revised Privacy Policy. If you do not agree to the updated terms, you must discontinue use of our services and may request account closure and data deletion by contacting our support team.
If you have any questions, concerns, or requests regarding this Privacy Policy or our data handling practices, please contact the spin39 Data Protection team through the following channels:
All data-related requests are handled by our dedicated privacy team. We are committed to responding to all inquiries within 30 days of receipt. For complex requests requiring additional verification, we may request proof of identity before processing your request to protect the security of your data.
Your Privacy Matters: At spin39, your trust is the foundation of everything we do. We handle your personal data with the same level of care we would want applied to our own. If at any point you feel your privacy has not been respected, please contact us immediately — we are committed to making it right.
Adults Only (21+): spin39 is exclusively for users aged 21 and above. If you are concerned about a minor accessing this platform, please contact us at [email protected] and use parental controls on your devices.
Our support team is available around the clock to answer any questions about your privacy rights, data requests, or account security. You can also review our full Terms and Conditions or visit our FAQ for quick answers.