Privacy Policy

Last updated: January 2026

1. Who we are

Spinalto is operated by Stegi Limitada Sociedad De Responsabilidad Limitada, registered in Costa Rica. For privacy enquiries you can reach us at support@spinalto.com.

2. Data we collect

• Account data: name, date of birth, address, email, phone, country, currency.
• Verification data (KYC): copies of identity documents, address proof, payment proof and where required source-of-funds evidence.
• Financial data: deposit and withdrawal records, payment instrument data (tokenised, no full card numbers), crypto wallet addresses.
• Activity data: bets placed, games played, login times, session duration, device type, IP address, browser fingerprint.
• Communication data: chat transcripts, emails and contact-form submissions exchanged with our support team.
• Marketing preferences: whether you have opted in or out of email, SMS and push notifications.

3. How we use your data

• Open, run and secure your account
• Process deposits and withdrawals
• Verify identity, age and address (KYC) and meet AML obligations
• Detect and prevent fraud, multi-accounting and abuse
• Provide customer support and respond to enquiries
• Send service messages (security, balance, account changes)
• Send marketing where you have opted in - you can opt out at any time
• Comply with legal, regulatory and tax requirements

4. Lawful basis

We process personal data on the following bases: contract (to provide the service you signed up for), legal obligation (KYC, AML, regulatory reporting), legitimate interest (fraud prevention, service security, internal analytics) and consent (marketing communications, optional cookies).

5. Sharing data

We share your data only with:

• Game providers and live dealer studios powering the platform
• Payment processors and crypto on-ramp partners handling your transactions
• KYC and identity verification providers
• Cloud and infrastructure providers hosting the platform
• Regulators, auditors and law-enforcement bodies where required

We do not sell your data to third parties.

6. International transfers

Some processors operate outside your country of residence. Where data leaves the EEA, we rely on appropriate safeguards (Standard Contractual Clauses, adequacy decisions or equivalent mechanisms).

7. Retention

Account, KYC and transaction data is retained for as long as you hold an account and for at least 5 years after closure to comply with AML legislation. Marketing data is deleted when you opt out. Support transcripts are kept for 24 months.

8. Your rights

• Access - request a copy of the personal data we hold about you.
• Correction - have inaccurate data corrected.
• Erasure - request deletion of data, subject to legal retention rules.
• Restriction - request that we stop processing certain data.
• Objection - object to processing based on legitimate interest, including profiling.
• Portability - receive your data in a portable format.
• Withdraw consent - opt out of marketing or other consent-based processing at any time.
• Complaint - lodge a complaint with your local data protection authority.

To exercise any of these rights, email support@spinalto.com. We respond within 30 days.

9. Cookies

We use cookies for essential session management, security and analytics. Marketing cookies are only set with your consent. You can manage cookie preferences via our cookie banner or your browser settings.

10. Security

We use TLS encryption in transit, encrypted storage at rest, tokenised payment data, role-based access control and 2FA for staff. No system is completely secure - if we ever detect a breach affecting your data, we will notify you and the relevant authorities as required by law.

11. Children

Spinalto is for adults only (18+). We do not knowingly collect personal data from minors. If we discover that a minor has registered, the account is closed and any data is deleted (subject to AML retention obligations).

12. Changes to this policy

We may update this policy from time to time. The latest version is always available on this page with the date at the top.

13. Contact

For privacy questions, write to support@spinalto.com.