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Privacy Policy

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PRIVACY POLICY


Last Updated: 27 July 2026


1. Introduction


This Privacy Policy explains how MB Stonebridge Solutions LTD ("Company", "we", "our", or "us") collects, uses, stores, shares, and otherwise processes personal data when you access or use FunSpin Games ("FunSpin Games", the "Platform", the "Website", or the "Service").


FunSpin Games is a social gaming platform that provides entertainment games using virtual Coins. The Platform may also offer user profiles, leaderboards, promotional bonuses, chat requests, private messaging, and other community features.


We are committed to protecting your privacy and processing your personal data lawfully, fairly, transparently, and securely in accordance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable laws of the Republic of Lithuania.


This Privacy Policy applies to personal data processed in connection with:


     
  • the Website available at funspingames.com;
    •  
  • registration and management of user Accounts;
    •  
  • games and gameplay activity;
    •  
  • purchases and use of Coins;
    •  
  • Welcome Bonuses and Daily Bonuses;
    •  
  • user profiles and leaderboards;
    •  
  • chat requests and private messaging;
    •  
  • customer support;
    •  
  • marketing communications;
    •  
  • fraud prevention and Platform security;
    •  
  • cookies and similar technologies; and
    •  
  • other features and services made available through FunSpin Games.

    • This Privacy Policy should be read together with our Terms of Service, Cookie Policy, Refund Policy, Responsible Social Gaming Policy, Community Guidelines, and any other policies or notices published on the Platform.


    2. Data Controller


    For the purposes of applicable data protection legislation, the controller responsible for processing your personal data is:


    MB Stonebridge Solutions LTD


    Registration number: 308059377


    Registered office:


    V. Nagevičiaus g. 3

    LT-08237 Vilnius
    Lithuania


    Website: funspingames.com


    Email: info@funspingames.com


    Telephone: +44 7403 629891


    Questions, requests, or complaints concerning the processing of personal data may be sent to info@funspingames.com.


    We have not appointed a separate Data Protection Officer unless and until such an appointment is required by applicable law. Privacy enquiries may therefore be addressed directly to the Company using the contact details above.


    3. Personal Data We Collect


    We collect personal data that you provide directly, data generated when you use the Platform, and data received from service providers and other permitted sources.


    The personal data we collect depends on how you interact with FunSpin Games.


    3.1 Account and registration information


    When you create or manage an Account, we may collect:


       
    • your name, where provided;
      •  
    • username or display name;
      •  
    • email address;
      •  
    • password in encrypted or hashed form;
      •  
    • date of birth or age confirmation;
      •  
    • country or region;
      •  
    • language preference;
      •  
    • Account creation date;
      •  
    • email verification status;
      •  
    • Account settings;
      •  
    • marketing preferences; and
      •  
    • other information that you voluntarily add to your Account.

      • We may ask you to verify your email address, age, identity, location, or ownership of an Account where reasonably necessary for security, fraud prevention, payment processing, or compliance purposes.


      3.2 Profile information


      Depending on the features available, you may choose to provide:


         
      • a username;
        •  
      • profile picture or avatar;
        •  
      • profile description;
        •  
      • gaming preferences;
        •  
      • achievements;
        •  
      • leaderboard information;
        •  
      • game statistics;
        •  
      • friend or contact connections; and
        •  
      • other information displayed on your Platform profile.

        • Certain profile information may be visible to other registered users. You should avoid including sensitive or identifying information in any public profile field.


        3.3 Gameplay and Coins information


        When you participate in games or use Coins, we may collect:


           
        • current and previous Coin balances;
          •  
        • Coin purchase history;
          •  
        • Coins received through bonuses or promotions;
          •  
        • Coins used during gameplay;
          •  
        • game selections;
          •  
        • game outcomes;
          •  
        • gameplay history;
          •  
        • scores;
          •  
        • achievements;
          •  
        • rankings;
          •  
        • leaderboard participation;
          •  
        • session duration;
          •  
        • interactions with games and Platform features;
          •  
        • bonus claim history; and
          •  
        • information about technical errors affecting gameplay or Coins.

          • Coins are virtual entertainment items and have no cash or redemption value. However, records concerning Coins may still be connected to your Account and therefore constitute personal data.


          3.4 Welcome Bonus and Daily Bonus information


          When you receive, claim, or attempt to claim a Welcome Bonus, Daily Bonus, login reward, or other promotion, we may collect and process:


             
          • bonus eligibility status;
            •  
          • Account registration date;
            •  
          • bonus claim date and time;
            •  
          • consecutive login history;
            •  
          • bonus amount;
            •  
          • device and network information;
            •  
          • verification status;
            •  
          • previous promotional participation;
            •  
          • records of revoked or adjusted bonuses; and
            •  
          • information used to identify multiple-Account or bonus abuse.

            • We use this information to administer promotional offers, confirm eligibility, apply bonuses, prevent duplicate claims, investigate technical errors, and protect the integrity of the Platform.


            3.5 Chat requests and messaging information


            Where chat functionality is available, we may process:


               
            • chat requests sent and received;
              •  
            • the date and time of each chat request;
              •  
            • whether a request was accepted, declined, ignored, withdrawn, or blocked;
              •  
            • private messages sent after chat confirmation;
              •  
            • message timestamps;
              •  
            • message delivery status;
              •  
            • user reports;
              •  
            • block lists;
              •  
            • moderation actions;
              •  
            • safety-related records; and
              •  
            • technical information needed to deliver communications.

              • Private chat may become available only after the intended recipient affirmatively accepts or confirms the chat request.


              A user's decision to decline, ignore, withdraw, or block a chat request may be recorded so that we can enforce the user's preference, prevent repeated unwanted contact, and protect Platform users.


              We do not sell the contents of private messages or use private messages for unrelated advertising purposes.


              Messages may be accessed or reviewed only where reasonably necessary and permitted by law, including to:


                 
              • deliver the communication;
                •  
              • investigate a user report;
                •  
              • detect fraud, spam, scams, threats, or harassment;
                •  
              • enforce our Terms of Service and Community Guidelines;
                •  
              • protect users or the Platform;
                •  
              • troubleshoot technical issues;
                •  
              • comply with a lawful request; or
                •  
              • establish, exercise, or defend legal claims.

                • Not every message is manually reviewed.


                3.6 Payment and transaction information


                When you purchase Coins, payments may be processed by an authorised third-party payment service provider.


                We may receive:


                   
                • transaction identifier;
                  •  
                • transaction date and time;
                  •  
                • purchase amount;
                  •  
                • currency;
                  •  
                • quantity of Coins purchased;
                  •  
                • payment status;
                  •  
                • payment method type;
                  •  
                • billing country;
                  •  
                • payment-provider response;
                  •  
                • chargeback or refund status;
                  •  
                • limited payment-account identifiers;
                  •  
                • fraud-screening results; and
                  •  
                • information necessary to investigate a payment dispute.

                  • We do not intend to store complete payment card numbers, card verification values, or online banking credentials. Such information is processed by the relevant payment provider.


                  3.7 Customer support and communications


                  When you contact us, we may collect:


                     
                  • your name;
                    •  
                  • email address;
                    •  
                  • Account details;
                    •  
                  • the contents of your enquiry;
                    •  
                  • attachments or screenshots;
                    •  
                  • transaction information;
                    •  
                  • correspondence history;
                    •  
                  • complaint details;
                    •  
                  • technical information;
                    •  
                  • safety reports; and
                    •  
                  • any other information you choose to provide.

                    • Please do not send identification documents, payment card details, passwords, or other sensitive information unless we have specifically requested the information through an appropriate secure method.


                    3.8 Technical and device information


                    When you access the Platform, we may automatically collect:


                       
                    • IP address;
                      •  
                    • device type;
                      •  
                    • browser type and version;
                      •  
                    • operating system;
                      •  
                    • device identifiers;
                      •  
                    • screen resolution;
                      •  
                    • language settings;
                      •  
                    • time zone;
                      •  
                    • network information;
                      •  
                    • session identifiers;
                      •  
                    • referring website;
                      •  
                    • pages visited;
                      •  
                    • links and buttons selected;
                      •  
                    • login dates and times;
                      •  
                    • session duration;
                      •  
                    • crash reports;
                      •  
                    • error logs;
                      •  
                    • security events; and
                      •  
                    • other technical information concerning your interaction with the Platform.

                      • 3.9 Cookies and similar technologies


                      We may use:


                         
                      • cookies;
                        •  
                      • local storage;
                        •  
                      • pixels;
                        •  
                      • tags;
                        •  
                      • scripts;
                        •  
                      • software development kits;
                        •  
                      • device identifiers; and
                        •  
                      • similar technologies.

                        • These technologies may collect information about your device, browser, preferences, sessions, authentication, Platform activity, and interactions with our services.


                        More detailed information will be provided in our Cookie Policy and cookie preference interface.


                        3.10 Marketing information


                        Where you subscribe to marketing communications or otherwise permit us to contact you, we may collect:


                           
                        • email address;
                          •  
                        • subscription status;
                          •  
                        • consent records;
                          •  
                        • communication preferences;
                          •  
                        • emails sent;
                          •  
                        • delivery status;
                          •  
                        • email opens and link interactions, where permitted;
                          •  
                        • promotional participation; and
                          •  
                        • opt-out or unsubscribe records.

                          • 4. How We Collect Personal Data


                          We collect personal data through the following sources.


                          4.1 Directly from you


                          We collect information directly from you when you:


                             
                          • create or update an Account;
                            •  
                          • verify your email address;
                            •  
                          • purchase Coins;
                            •  
                          • claim a bonus;
                            •  
                          • participate in games;
                            •  
                          • create or update a profile;
                            •  
                          • send or accept a chat request;
                            •  
                          • send messages;
                            •  
                          • report or block another user;
                            •  
                          • contact customer support;
                            •  
                          • participate in a survey or promotion;
                            •  
                          • subscribe to marketing communications; or
                            •  
                          • otherwise interact with the Platform.

                            • 4.2 Automatically through the Platform


                            We automatically receive certain information when you use FunSpin Games, including gameplay records, Coin activity, bonus history, device information, log data, security events, cookie data, and technical information.


                            4.3 From service providers


                            We may receive personal data from service providers that assist with:


                               
                            • payment processing;
                              •  
                            • hosting and cloud infrastructure;
                              •  
                            • email delivery;
                              •  
                            • authentication;
                              •  
                            • customer support;
                              •  
                            • analytics;
                              •  
                            • error monitoring;
                              •  
                            • fraud prevention;
                              •  
                            • cybersecurity;
                              •  
                            • marketing; and
                              •  
                            • communication functionality.

                              • 4.4 From other users


                              We may receive information about you when another user:


                                 
                              • sends you a chat request;
                                •  
                              • communicates with you;
                                •  
                              • blocks you;
                                •  
                              • reports your Account or conduct;
                                •  
                              • refers to you in a support request; or
                                •  
                              • provides evidence concerning an alleged breach of our policies.

                                • We assess such information before taking any material enforcement action.


                                5. Purposes and Legal Bases for Processing


                                We process personal data only where we have an appropriate legal basis.


                                Depending on the relevant activity, the legal basis may be performance of a contract, compliance with a legal obligation, our legitimate interests, your consent, or protection of vital interests.


                                5.1 Creating and managing your Account


                                We process registration, login, profile, and Account information to:


                                   
                                • create your Account;
                                  •  
                                • authenticate you;
                                  •  
                                • maintain your Account;
                                  •  
                                • provide requested features;
                                  •  
                                • remember your preferences; and
                                  •  
                                • communicate essential service information.

                                  • Legal basis: performance of our contract with you.


                                  5.2 Providing games and managing Coins


                                  We process gameplay and Coin information to:


                                     
                                  • provide games;
                                    •  
                                  • calculate game outcomes;
                                    •  
                                  • update Coin balances;
                                    •  
                                  • record Coin transactions;
                                    •  
                                  • maintain achievements and rankings;
                                    •  
                                  • investigate gameplay errors; and
                                    •  
                                  • provide requested Platform functionality.

                                    • Legal basis: performance of our contract with you.


                                    5.3 Processing Coin purchases


                                    We process payment and transaction information to:


                                       
                                    • process purchases;
                                      •  
                                    • deliver Coins;
                                      •  
                                    • confirm payment status;
                                      •  
                                    • issue permitted refunds;
                                      •  
                                    • investigate disputes;
                                      •  
                                    • maintain financial records; and
                                      •  
                                    • respond to purchase enquiries.

                                      • Legal bases: performance of our contract, compliance with legal obligations, and our legitimate interests in preventing payment fraud and resolving disputes.


                                      5.4 Providing Welcome Bonuses and Daily Bonuses


                                      We process Account, device, login, and bonus information to:


                                         
                                      • determine eligibility;
                                        •  
                                      • apply bonuses;
                                        •  
                                      • manage consecutive-login rewards;
                                        •  
                                      • prevent duplicate claims;
                                        •  
                                      • identify multiple-Account abuse;
                                        •  
                                      • correct technical errors; and
                                        •  
                                      • enforce promotional conditions.

                                        • Legal bases: performance of our contract and our legitimate interests in operating promotions fairly and preventing abuse.


                                        5.5 Providing chat and community features


                                        We process profile information, chat requests, confirmations, messages, reports, and block records to:


                                           
                                        • send chat requests;
                                          •  
                                        • record whether a request was accepted or declined;
                                          •  
                                        • enable messaging after confirmation;
                                          •  
                                        • deliver messages;
                                          •  
                                        • enforce user blocks;
                                          •  
                                        • allow users to report misconduct;
                                          •  
                                        • protect users from unwanted communications; and
                                          •  
                                        • maintain community functionality.

                                          • Legal bases: performance of our contract and our legitimate interests in providing safe and effective community features.


                                          5.6 Moderation and user safety


                                          We may process messages, reports, Account history, device information, and related evidence to:


                                             
                                          • investigate harassment or threats;
                                            •  
                                          • detect scams and spam;
                                            •  
                                          • prevent attempts to circumvent chat confirmation or blocking;
                                            •  
                                          • identify illegal or harmful content;
                                            •  
                                          • enforce our Terms and Community Guidelines; and
                                            •  
                                          • protect the rights and safety of users.

                                            • Legal bases: our legitimate interests, compliance with legal obligations, and, in exceptional cases, protection of vital interests.


                                            5.7 Security and fraud prevention


                                            We process technical, Account, payment, Coin, bonus, and gameplay information to:


                                               
                                            • prevent unauthorised access;
                                              •  
                                            • identify multiple Accounts;
                                              •  
                                            • detect automated activity;
                                              •  
                                            • prevent payment fraud;
                                              •  
                                            • detect chargeback abuse;
                                              •  
                                            • investigate gameplay manipulation;
                                              •  
                                            • maintain Platform integrity;
                                              •  
                                            • protect our systems; and
                                              •  
                                            • establish, exercise, or defend legal claims.

                                              • Legal bases: our legitimate interests and compliance with legal obligations.


                                              5.8 Customer support


                                              We process information contained in support requests to:


                                                 
                                              • respond to questions;
                                                •  
                                              • resolve complaints;
                                                •  
                                              • investigate technical problems;
                                                •  
                                              • restore access where appropriate;
                                                •  
                                              • investigate disputed payments;
                                                •  
                                              • respond to privacy requests; and
                                                •  
                                              • maintain support records.

                                                • Legal bases: performance of our contract, our legitimate interests, compliance with legal obligations, and steps taken at your request.


                                                5.9 Service improvement and analytics


                                                We process usage, gameplay, technical, and aggregated information to:


                                                   
                                                • understand how the Platform is used;
                                                  •  
                                                • measure performance;
                                                  •  
                                                • identify errors;
                                                  •  
                                                • improve games and functionality;
                                                  •  
                                                • develop new features;
                                                  •  
                                                • analyse general user trends; and
                                                  •  
                                                • maintain a reliable service.

                                                  • Legal bases: our legitimate interests and, where required for non-essential analytics technologies, your consent.


                                                  Where reasonably possible, we use aggregated or anonymised information for analytical purposes.


                                                  5.10 Marketing communications


                                                  We may process your email address and marketing preferences to send information about:


                                                     
                                                  • new games;
                                                    •  
                                                  • Platform features;
                                                    •  
                                                  • promotional offers;
                                                    •  
                                                  • bonuses;
                                                    •  
                                                  • community events; and
                                                    •  
                                                  • other FunSpin Games updates.

                                                    • Legal basis: your consent where consent is required by law, or another lawful basis permitted for existing customer communications.


                                                    You may withdraw your consent or unsubscribe at any time.


                                                    5.11 Compliance with legal obligations


                                                    We may process and retain personal data to:


                                                       
                                                    • comply with accounting and taxation requirements;
                                                      •  
                                                    • respond to lawful requests;
                                                      •  
                                                    • manage consumer complaints;
                                                      •  
                                                    • investigate suspected unlawful conduct;
                                                      •  
                                                    • comply with court orders;
                                                      •  
                                                    • respond to supervisory authorities; and
                                                      •  
                                                    • maintain legally required records.

                                                      • Legal basis: compliance with a legal obligation.


                                                      6. Legitimate Interests


                                                      Where we rely on legitimate interests, those interests may include:


                                                         
                                                      • operating and improving FunSpin Games;
                                                        •  
                                                      • providing a secure gaming environment;
                                                        •  
                                                      • protecting users from abuse and scams;
                                                        •  
                                                      • preventing fraud and payment misuse;
                                                        •  
                                                      • preventing multiple-Account and bonus abuse;
                                                        •  
                                                      • enforcing chat confirmation and blocking preferences;
                                                        •  
                                                      • maintaining accurate Coin balances;
                                                        •  
                                                      • investigating technical errors;
                                                        •  
                                                      • protecting our legal rights;
                                                        •  
                                                      • securing our systems;
                                                        •  
                                                      • understanding Platform performance; and
                                                        •  
                                                      • communicating important service information.

                                                        • Before relying on legitimate interests, we consider whether the processing is necessary and whether your interests, rights, or freedoms override our interests.


                                                        You may have the right to object to processing based on legitimate interests, as explained below.


                                                        7. Chat Privacy and User Safety


                                                        Private messaging is available only where supported by the Platform and may require confirmation from the intended recipient.


                                                        When you send a chat request, the recipient may see information such as:


                                                           
                                                        • your username;
                                                          •  
                                                        • avatar;
                                                          •  
                                                        • limited profile information;
                                                          •  
                                                        • the date or time of the request; and
                                                          •  
                                                        • any short introductory information permitted by the Platform.

                                                          • The recipient may accept, decline, ignore, report, or block the request.


                                                          If the request is accepted, both users may exchange messages through the Platform.


                                                          Acceptance of a chat request does not make the conversation public and does not permit either user to misuse the other person's personal information.


                                                          You should not share the following through chat:


                                                             
                                                          • passwords;
                                                            •  
                                                          • authentication codes;
                                                            •  
                                                          • full payment card details;
                                                            •  
                                                          • bank account credentials;
                                                            •  
                                                          • identification documents;
                                                            •  
                                                          • precise residential addresses;
                                                            •  
                                                          • private financial information; or
                                                            •  
                                                          • information that could create a risk to your safety.

                                                            • Other users are independent users of the Platform. We are not responsible for personal data that you voluntarily disclose to another user outside the functionality and reasonable control of the Platform.


                                                            We may retain records of declined requests, blocks, user reports, and moderation actions where necessary to respect user choices, prevent repeated unwanted contact, investigate abuse, and maintain Platform safety.


                                                            8. Automated Systems


                                                            We may use automated tools to:


                                                               
                                                            • detect suspicious login activity;
                                                              •  
                                                            • identify multiple Accounts;
                                                              •  
                                                            • flag potential bonus abuse;
                                                              •  
                                                            • identify unusual payment behaviour;
                                                              •  
                                                            • detect spam or automated messaging;
                                                              •  
                                                            • detect potentially harmful content;
                                                              •  
                                                            • identify technical errors; and
                                                              •  
                                                            • prioritise matters for investigation.

                                                              • Automated systems may generate alerts or temporarily restrict certain activity while a matter is reviewed.


                                                              Unless specifically disclosed otherwise, we do not intend to make decisions based solely on automated processing that produce legal effects or similarly significant effects concerning users.


                                                              Where applicable law provides a right to obtain human intervention, express your point of view, or challenge an automated decision, you may contact us at info@funspingames.com.


                                                              9. Cookies and Similar Technologies


                                                              We use cookies and similar technologies to operate, secure, personalise, and analyse the Platform.


                                                              9.1 Essential cookies


                                                              Essential cookies are necessary to:


                                                                 
                                                              • maintain login sessions;
                                                                •  
                                                              • authenticate users;
                                                                •  
                                                              • protect Accounts;
                                                                •  
                                                              • prevent fraud;
                                                                •  
                                                              • remember security settings;
                                                                •  
                                                              • maintain Coin and gameplay sessions; and
                                                                •  
                                                              • provide core Website functionality.

                                                                • These technologies may be used without consent where permitted because they are necessary to provide the service requested by the user.


                                                                9.2 Functional cookies


                                                                Functional cookies may remember:


                                                                   
                                                                • language preferences;
                                                                  •  
                                                                • display preferences;
                                                                  •  
                                                                • selected settings;
                                                                  •  
                                                                • previous choices; and
                                                                  •  
                                                                • other personalisation features.

                                                                  • 9.3 Analytics and performance cookies


                                                                  Analytics and performance cookies may help us understand:


                                                                     
                                                                  • which pages users visit;
                                                                    •  
                                                                  • which games and features are used;
                                                                    •  
                                                                  • how users navigate the Platform;
                                                                    •  
                                                                  • whether errors occur;
                                                                    •  
                                                                  • how quickly pages load; and
                                                                    •  
                                                                  • how the Platform performs.

                                                                    • Where required by law, these cookies will be placed only after you provide consent.


                                                                    9.4 Marketing cookies


                                                                    Marketing technologies may be used to measure campaigns, understand promotional engagement, or provide relevant advertisements.


                                                                    Where required, marketing cookies will be used only with your consent.


                                                                    You may manage non-essential cookies through our cookie preference interface. You may also adjust browser settings, although blocking certain cookies may affect Platform functionality.


                                                                    Further information will be provided in our Cookie Policy.


                                                                    10. Marketing Communications


                                                                    We may send marketing communications only where permitted by applicable law.


                                                                    Marketing communications may concern new games, bonus offers, Platform updates, community events, or other FunSpin Games services.


                                                                    You may unsubscribe by:


                                                                       
                                                                    • selecting the unsubscribe option in a marketing email;
                                                                      •  
                                                                    • changing your Account preferences, where available; or
                                                                      •  
                                                                    • contacting info@funspingames.com.

                                                                      • Withdrawing consent does not affect essential service messages relating to Account security, transactions, changes to legal terms, privacy matters, or important Platform notices.


                                                                      We maintain limited suppression records after an unsubscribe request to ensure that the user is not added back to marketing communications unintentionally.


                                                                      11. Sharing Personal Data


                                                                      We do not sell personal data.


                                                                      We may share personal data with trusted service providers where necessary to operate the Platform.


                                                                      11.1 Payment providers


                                                                      Payment providers may process personal data to:


                                                                         
                                                                      • complete Coin purchases;
                                                                        •  
                                                                      • verify transactions;
                                                                        •  
                                                                      • prevent fraud;
                                                                        •  
                                                                      • manage refunds;
                                                                        •  
                                                                      • investigate chargebacks; and
                                                                        •  
                                                                      • comply with payment and financial obligations.

                                                                        • 11.2 Hosting and technology providers


                                                                        We may use hosting, cloud, database, content-delivery, security, monitoring, and infrastructure providers to operate and protect the Platform.


                                                                        11.3 Communication providers


                                                                        Email, messaging, notification, and customer-support providers may process contact details and communications necessary to deliver their services.


                                                                        11.4 Analytics providers


                                                                        Analytics providers may process device, cookie, and usage information to help us understand Platform activity and performance.


                                                                        Non-essential analytics will be subject to consent where required.


                                                                        11.5 Fraud-prevention and security providers


                                                                        We may share limited Account, device, payment, and transaction information with providers that help us identify:


                                                                           
                                                                        • unauthorised transactions;
                                                                          •  
                                                                        • compromised Accounts;
                                                                          •  
                                                                        • multiple-Account abuse;
                                                                          •  
                                                                        • automated activity;
                                                                          •  
                                                                        • payment fraud; and
                                                                          •  
                                                                        • other security threats.

                                                                          • 11.6 Professional advisers


                                                                          Personal data may be disclosed to lawyers, accountants, auditors, insurers, and other professional advisers where reasonably necessary for legal, compliance, financial, or business purposes.


                                                                          11.7 Authorities and legal disclosures


                                                                          We may disclose personal data where required or permitted by law, including in response to:


                                                                             
                                                                          • a court order;
                                                                            •  
                                                                          • a lawful regulatory request;
                                                                            •  
                                                                          • a request from law enforcement;
                                                                            •  
                                                                          • an investigation into suspected unlawful activity;
                                                                            •  
                                                                          • an immediate safety threat; or
                                                                            •  
                                                                          • a need to establish, exercise, or defend legal claims.

                                                                            • 11.8 Corporate transactions


                                                                            If the Company is involved in a merger, acquisition, restructuring, financing, sale of assets, or transfer of the Platform, personal data may be disclosed or transferred as part of that transaction.


                                                                            Appropriate confidentiality and data-protection measures will be applied.


                                                                            Service providers acting on our behalf are required to process personal data only in accordance with our documented instructions, applicable contracts, and data-protection law.


                                                                            12. International Data Transfers


                                                                            Some service providers may process personal data outside Lithuania or the European Economic Area.


                                                                            Where personal data is transferred to a country that has not been recognised as providing an adequate level of protection, we will use an appropriate lawful transfer mechanism where required, such as:


                                                                               
                                                                            • European Commission adequacy decisions;
                                                                              •  
                                                                            • Standard Contractual Clauses;
                                                                              •  
                                                                            • supplementary technical or organisational safeguards;
                                                                              •  
                                                                            • binding corporate rules, where applicable; or
                                                                              •  
                                                                            • another legally recognised transfer mechanism.

                                                                              • You may contact us for further information about the safeguards applied to relevant international transfers.


                                                                              13. Data Retention


                                                                              We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.


                                                                              Retention periods depend on:


                                                                                 
                                                                              • the type of personal data;
                                                                                •  
                                                                              • the duration of your Account;
                                                                                •  
                                                                              • the reason the information was collected;
                                                                                •  
                                                                              • applicable legal requirements;
                                                                                •  
                                                                              • security and fraud-prevention needs;
                                                                                •  
                                                                              • limitation periods for legal claims; and
                                                                                •  
                                                                              • whether an active complaint or dispute exists.

                                                                                • 13.1 Account information


                                                                                Account information is generally retained while your Account remains active.


                                                                                After Account closure, certain information may be retained where necessary for legal compliance, fraud prevention, dispute resolution, enforcement of our Terms, or protection of users.


                                                                                13.2 Payment records


                                                                                Transaction, refund, and accounting records may be retained for the period required under applicable tax, accounting, consumer-protection, and financial laws.


                                                                                13.3 Gameplay and Coin records


                                                                                Gameplay and Coin records may be retained while the Account is active and for an appropriate period afterwards to:


                                                                                   
                                                                                • resolve disputes;
                                                                                  •  
                                                                                • investigate technical errors;
                                                                                  •  
                                                                                • prevent abuse;
                                                                                  •  
                                                                                • maintain transaction integrity; and
                                                                                  •  
                                                                                • defend legal claims.

                                                                                  • 13.4 Bonus records


                                                                                  Welcome Bonus, Daily Bonus, device, and promotional eligibility records may be retained for as long as reasonably necessary to prevent repeat claims, multiple-Account abuse, fraud, and technical errors.


                                                                                  13.5 Chat information


                                                                                  Chat requests, confirmations, messages, blocks, and related technical records may be retained for the period necessary to provide messaging functionality and maintain Platform security.


                                                                                  Messages or moderation evidence may be retained for longer where:


                                                                                     
                                                                                  • a report has been submitted;
                                                                                    •  
                                                                                  • misconduct is being investigated;
                                                                                    •  
                                                                                  • a legal claim or dispute exists;
                                                                                    •  
                                                                                  • preservation is required by law; or
                                                                                    •  
                                                                                  • the information is necessary to protect a user.

                                                                                    • 13.6 Support and complaint records


                                                                                    Support correspondence may be retained for a reasonable period after the matter is resolved to maintain service history, manage repeated issues, comply with legal obligations, and defend claims.


                                                                                    13.7 Marketing records


                                                                                    Marketing consent and opt-out records may be retained for as long as necessary to demonstrate compliance with your preferences.


                                                                                    When personal data is no longer required, it will be deleted, anonymised, or securely restricted in accordance with our retention procedures.


                                                                                    14. Data Security


                                                                                    We use appropriate technical and organisational measures designed to protect personal data against:


                                                                                       
                                                                                    • unauthorised access;
                                                                                      •  
                                                                                    • accidental loss;
                                                                                      •  
                                                                                    • unlawful disclosure;
                                                                                      •  
                                                                                    • alteration;
                                                                                      •  
                                                                                    • misuse;
                                                                                      •  
                                                                                    • destruction; and
                                                                                      •  
                                                                                    • other unlawful processing.

                                                                                      • Measures may include:


                                                                                         
                                                                                      • encryption where appropriate;
                                                                                        •  
                                                                                      • secure password storage;
                                                                                        •  
                                                                                      • access controls;
                                                                                        •  
                                                                                      • authentication procedures;
                                                                                        •  
                                                                                      • logging and monitoring;
                                                                                        •  
                                                                                      • backups;
                                                                                        •  
                                                                                      • network security;
                                                                                        •  
                                                                                      • vulnerability management;
                                                                                        •  
                                                                                      • staff and contractor confidentiality obligations;
                                                                                        •  
                                                                                      • provider due diligence; and
                                                                                        •  
                                                                                      • incident-response procedures.

                                                                                        • Access to personal data is limited to persons and providers that require access for legitimate business purposes.


                                                                                        No online system can be guaranteed to be completely secure. You are responsible for maintaining the confidentiality of your password and should notify us promptly if you suspect unauthorised access to your Account.


                                                                                        Where a personal data breach occurs, we will assess the risks and notify the competent supervisory authority and affected individuals where required by applicable law.


                                                                                        15. Your Data Protection Rights


                                                                                        Subject to applicable law and relevant conditions, you may have the following rights.


                                                                                        15.1 Right of access


                                                                                        You may request confirmation as to whether we process your personal data and request a copy of the personal data we hold about you.


                                                                                        15.2 Right to rectification


                                                                                        You may ask us to correct personal data that is inaccurate or complete information that is incomplete.


                                                                                        15.3 Right to erasure


                                                                                        You may ask us to delete personal data in certain circumstances.


                                                                                        The right to erasure is not absolute. We may retain information where processing remains necessary for legal compliance, fraud prevention, safety, legal claims, or another lawful purpose.


                                                                                        15.4 Right to restriction


                                                                                        You may ask us to restrict the processing of personal data in certain circumstances, including while the accuracy or lawfulness of processing is being assessed.


                                                                                        15.5 Right to data portability


                                                                                        Where processing is based on consent or a contract and is carried out by automated means, you may have the right to receive certain personal data in a structured, commonly used, and machine-readable format.


                                                                                        You may also ask us to transmit that information to another controller where technically feasible.


                                                                                        15.6 Right to object


                                                                                        You may object to processing based on legitimate interests where your particular circumstances justify the objection.


                                                                                        We may continue processing where we demonstrate compelling legitimate grounds or where processing is required for legal claims.


                                                                                        You have the right to object to direct marketing at any time.


                                                                                        15.7 Right to withdraw consent


                                                                                        Where processing is based on consent, you may withdraw consent at any time.


                                                                                        Withdrawal does not affect processing carried out lawfully before consent was withdrawn.


                                                                                        15.8 Rights relating to automated decision-making


                                                                                        Where applicable, you may have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects.


                                                                                        15.9 Right to complain


                                                                                        You have the right to lodge a complaint with a competent data-protection supervisory authority.


                                                                                        As the Company is established in Lithuania, you may contact:


                                                                                        State Data Protection Inspectorate of the Republic of Lithuania


                                                                                        L. Sapiegos str. 17

                                                                                        LT-10312 Vilnius
                                                                                        Lithuania


                                                                                        Email: ada@ada.lt


                                                                                        You may also have the right to contact the supervisory authority in the country where you live or work or where the alleged infringement occurred.


                                                                                        16. Exercising Your Rights


                                                                                        To exercise a privacy right, contact:


                                                                                        info@funspingames.com


                                                                                        Please describe the request clearly and provide the email address connected to your Account.


                                                                                        We may ask for additional information to verify your identity. This is intended to prevent unauthorised access to personal data.


                                                                                        We will respond within the period required by applicable law. In certain cases, the response period may be extended where a request is complex or multiple requests have been submitted. Where an extension is permitted, we will inform you.


                                                                                        Privacy requests are generally handled free of charge. We may charge a reasonable fee or refuse to act where a request is manifestly unfounded or excessive, as permitted by law.


                                                                                        17. Account Deletion


                                                                                        You may request deletion of your Account through any available Account settings or by contacting info@funspingames.com.


                                                                                        Account deletion may result in the loss of:


                                                                                           
                                                                                        • Coins;
                                                                                          •  
                                                                                        • bonus balances;
                                                                                          •  
                                                                                        • achievements;
                                                                                          •  
                                                                                        • rankings;
                                                                                          •  
                                                                                        • profile information;
                                                                                          •  
                                                                                        • chat access;
                                                                                          •  
                                                                                        • gameplay history; and
                                                                                          •  
                                                                                        • other Virtual Content.

                                                                                          • Deleting an Account does not necessarily result in immediate deletion of every record.


                                                                                          We may retain limited personal data where required for:


                                                                                             
                                                                                          • legal compliance;
                                                                                            •  
                                                                                          • accounting and taxation;
                                                                                            •  
                                                                                          • payment disputes;
                                                                                            •  
                                                                                          • fraud prevention;
                                                                                            •  
                                                                                          • user safety;
                                                                                            •  
                                                                                          • enforcement of our Terms;
                                                                                            •  
                                                                                          • legal claims; or
                                                                                            •  
                                                                                          • responding to supervisory authorities.

                                                                                            • Where possible, information retained after Account deletion will be restricted and used only for the applicable retention purpose.


                                                                                            18. Children's Privacy


                                                                                            FunSpin Games is intended only for individuals who are at least eighteen years old or who have reached the age of legal majority in their jurisdiction, whichever is higher.


                                                                                            The Platform is not directed to children, and we do not knowingly collect personal data from individuals who do not meet the minimum-age requirement.


                                                                                            If we learn that an underage individual has created an Account, we may:


                                                                                               
                                                                                            • suspend the Account;
                                                                                              •  
                                                                                            • request age verification;
                                                                                              •  
                                                                                            • terminate the Account;
                                                                                              •  
                                                                                            • remove associated Virtual Content; and
                                                                                              •  
                                                                                            • delete the relevant personal data, unless retention is legally required.

                                                                                              • A parent or legal guardian who believes that an underage person has provided personal data may contact info@funspingames.com.


                                                                                              19. Sensitive Personal Data


                                                                                              We do not intentionally request special categories of personal data, such as information concerning health, religion, political opinions, ethnicity, biometric identification, sexual orientation, or trade union membership.


                                                                                              Please do not include such information in your public profile, chat messages, support requests, or other User Content unless it is strictly necessary.


                                                                                              Where sensitive information is voluntarily provided, we will process it only where a valid legal basis exists and additional GDPR requirements are satisfied.


                                                                                              20. Third-Party Websites and Services


                                                                                              The Platform may contain links to websites or services operated by third parties.


                                                                                              Third parties operate independently and may collect personal data under their own privacy policies.


                                                                                              We are not responsible for the privacy practices, security, content, availability, or data processing activities of external services that we do not control.


                                                                                              You should review the privacy policy of any third-party website or service before providing personal data.


                                                                                              The use of a third-party provider to support FunSpin Games does not necessarily mean that the provider is endorsed for purposes unrelated to the Platform.


                                                                                              21. Changes to This Privacy Policy


                                                                                              We may update this Privacy Policy to reflect:


                                                                                                 
                                                                                              • changes to Platform functionality;
                                                                                                •  
                                                                                              • new games or community features;
                                                                                                •  
                                                                                              • changes to payment or bonus systems;
                                                                                                •  
                                                                                              • new service providers;
                                                                                                •  
                                                                                              • changes in legal requirements;
                                                                                                •  
                                                                                              • changes to our data-processing practices; or
                                                                                                •  
                                                                                              • security and operational developments.

                                                                                                • The latest version will be published on the Platform with an updated "Last Updated" date.


                                                                                                Where a change materially affects how personal data is processed, we will provide additional notice where required. Notice may be provided through:


                                                                                                   
                                                                                                • an email;
                                                                                                  •  
                                                                                                • an Account notification;
                                                                                                  •  
                                                                                                • a prominent Website notice; or
                                                                                                  •  
                                                                                                • another appropriate communication method.

                                                                                                  • Material changes will not be applied retroactively where doing so would be unlawful.


                                                                                                  22. Contact Us


                                                                                                  Questions, requests, complaints, or concerns regarding this Privacy Policy or the processing of personal data may be submitted to:


                                                                                                  MB Stonebridge Solutions LTD


                                                                                                  Registration number: 308059377


                                                                                                  Registered office:


                                                                                                  V. Nagevičiaus g. 3

                                                                                                  LT-08237 Vilnius
                                                                                                  Lithuania


                                                                                                  Website: funspingames.com


                                                                                                  Email: info@funspingames.com


                                                                                                  Telephone: +44 7403 629891

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