This page informs you of our policies regarding the collection, use,
and disclosure of Personal Data when you use our Service and the
choices you have associated with that data.
Your trust in us is highly valued, and we are grateful for your
decision to share your data with us. As a responsible business,
safeguarding your data is our utmost priority. Our goal is to maintain
your trust, and to achieve this, we take all necessary and reasonable
measures to protect any Personal Data you provide to us.
Definitions
About us
Data collection and use
Purposes and legal bases
Automated processing and profiling
Retention period
Security
Sharing personal data with third parties
International transfer
Your rights
Children's privacy
Cookies
Links to other sites
Changes to privacy notice
Data Controller –the natural or legal person who determines the
purposes for which and the manner in which Personal Data is, or is to
be, processed. For the purpose of this Privacy Notice, we are a Data
Controller of your Personal Data.
Personal Data –any information that relates to an identified or
identifiable individual.
European Economic Area (“EEA”)–the member states of the European Union
and three additional countries, namely Iceland, Liechtenstein, and
Norway.
Data Subject – any living individual who is using our Service and
provides us with the Personal Data.
Hitnspin.com is operated by ICS MANPOWER SOLUTIONS Ltd. registered in
the Republic of Cyprus; the address of the principal place of business
is 25, Voukourestiou, Neptune House, 1st floor, Flat/Office 11 Zakaki,
3045, Limassol, Cyprus.
Registration number: HE 445968.
All gambling services are licensed by TwiceDice B.V. (license
8048/JAZ2021-047).
Address: Korporaalweg 10, Willemstad, Curaçao. Registration number:
154842, which is the parent company in relation to ICS MANPOWER
SOLUTIONS Ltd.
Hitnspin is the controller of your personal data and is hereinafter
referred to as “Company”, “We”, “Us”, “Our”. You can contact us for
any issue relating to data processing via e-mail privacy@hitnspin.com.
We may process the following personal data categories: Contact data.
When you communicate with us via the interface of the Website or via
available contact details, you provide us with the following data:
name, surname, postal address/email address/phone number; any
information you provide us during our communication as well as history
of communication, which includes the record of audio calls with us
(for example, when you communicate via audio with our Support team
etc.)
Account data. When you create an account on the Website, you provide
us, in addition to your Contact data, with the following: date of
birth, gender, information about coupons you have activated; username
(if applicable), Skype account; any additional data you voluntarily
provide.
Newsletter consent data. We collect the data on whether have you
consented to receive our Newsletter.
Referral data. We collect the data about your referral (referral user
or the referral affiliate).
Bets data. These data include information about bets you have made and
on what outcomes, games you have played and the total amount of
winnings and losses and similar information.
Verification data. During the verification process you will be
required to provide us with the following data: a copy or a photo of
your identification document, payment instrument or other evidence
that you are a holder of a payment instrument used or intended to be
used for making transactions; a photo of you; utility or phone bills,
confirmation of the source of your wealth and your funds; record of
your video calls/audio-calls with the Website`s administration (if
verification is made via audio/video call).
Payment data. The Website uses SSL encryption that ensures the
confidentiality of your information in the transmission of data. The
payment operations are carried out entirely through the secure server
of the payment gateway. However, we may store your deposit and
withdrawal history and the limited payment information (for example,
the last four digits of your credit card, bank issuer, etc.). Loyalty
Program data. For the frequenters of the Website, we created our
Loyalty Program. It means that we create data about the participation
of the user within this Program. These data include: your points
earned, level, cashback amount and any data which may be processed
within the Loyalty Program.
Bonus data. We process the data about your use of the bonuses within
the Bonus Program. These data include, but not limited to information
about the bonus balance.
Automatically collected data. When you use the Services some data are
collected automatically. Such data include the following: total time
you spend on the Website, internal links were clicked (based on the
URL of the next pageview), your IP address and user agent string
(which browser is being used, what version, and on which operating
system).
Cookie data. Cookies may collect data that fall within the definition
of “personal data”. To find more information about the use of cookies,
please, follow our Cookie Notice.
To ensure the security of your account and to verify your identity, we
use third-party identity verification services such as Face
ID and Touch ID provided by your device manufacturer (e.g., Apple,
Android). These biometric authentication methods allow you to log in
securely without the need for passwords. Please note that your
biometric data (e.g., facial recognition or fingerprint information)
is processed solely on your device, and we do not access, store, or
process this biometric data. Only the authentication result (success
or failure) is shared with us to enable secure access to our
Services.
Purpose
Description
Legal basis
Providing our Services
We process your Personal Data to operate and administer our Service.
Necessary for the performance of a contract and our legitimate
interest in providing online content to our customers and prospective
customers regarding our Service.
Maintaining our security
We process your Personal Data for the purposes of maintaining own
security, including investigating, detecting and preventing suspicious
activity and fraud.
Our legitimate interest in promoting the safety and security generally
and to protect our rights and the rights of others.
Handling contacts and user support requests
We process your Personal Data, if you fill out a “Get in touch” web
form or request user support, or if you contact us by other means.
Necessary for the performance of a contract or our legitimate interest
in fulfilling your requests and communicating with you.
Improving our Service and conducting marketing activities
We collect your Personal Data in order to market our Service, in
particular to notify you of news and updates related to our business,
and perform market analysis/research.
Consent (if required under applicable law) and legitimate interest
(for instance, to create promotions you may be interested in).
We do not use automated processing and profiling which produces legal effects concerning you or similarly significantly affects you.
We will retain your Personal Data only for as long as necessary for
the purposes set out in this Privacy Notice. We will retain and use
your Personal Data to the extent necessary to fulfill our legal
obligations, resolve disputes, and enforce our legal agreements and
policies. Data from our users who have an account on the Site: six (6)
years from the date we close your account on the Site and terminate
our agreement with you.
We also retain Usage Data for internal
analysis purposes. Usage Data is generally retained for a shorter
period of time, unless the data is used to enhance the security or
functionality of our Services or we are required by law to retain the
data for a longer period of time.
We use reasonable measures to help protect data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Furthermore, we restrict access to your Personal Data to authorized personnel, agents, contractors, and relevant third parties who have a legitimate business requirement to access such information. They are obligated to process your Personal Data solely based on our instructions and are bound by confidentiality obligations.
Our subcontractors, affiliated companies and other entities. The
Website and Services provided via the Website are maintained and
provided by a large number of people who may be employed either by the
Company or by any of our affiliated companies, subcontractors, and
other establishments. This means that your data may be shared with
them. Please note that all these transfers are secured by proper data
transfer agreements which oblige these recipients to process your data
in accordance with this Policy and with the data protection
legislation to which the Company is subject. We engage service
providers for the following services:
Hosting the Website and data;
Marketing services;
IT services and security services;
Customer support software service providers;
Payment service providers;
KYC, anti-fraud, and anti-money laundering services;
Games providers;
Audit, legal and compliance services.
Data centre(s) which make the Website available. The Website and the
Services provided via the Website are placed on the Server which
belongs to the third party. From this follows that your data will be
shared with them. Please note that your data are stored only in
encrypted form, which makes it impossible to decrypt your data without
decryption keys.
Financial institutions: banks, payment services providers, payment
systems/gateways and other similar entities. Your transactions for the
Services provided via the Website are processed by the third-party
financial institution(s). This means that your data will be shared
with them to process your transactions and perform their legal and
regulatory obligations. Сourier companies. If you win any physical
winning(s) or prize(s), your data will be shared with a courier
company that will be engaged in the process of delivery of a winning
or a prize to you.
Accreditation bodies, auditors. When the Company passes an independent
audit, the data concerning you may be shared with the auditor. All
these bodies or auditors are legally obliged to handle your data in
accordance with this Policy and applicable legislation. Analytics. We
use data analytics services to measure and understand our audience,
tailor our marketing services, improve Website experience. This
includes Google Analytics and Hotjar.
Google Analytics. The Website uses Google Analytics, a web analytics
service. It is operated by Google LLC., 1600 Amphitheatre Parkway,
Mountain View, CA 94043, USA. Google Analytics uses previously
mentioned "cookies". The information generated by the cookie about
your use of the Website is usually transmitted to a Google server in
the USA and stored there. Google Analytics Opt-out Browser Add-on
provides visitors and users with the ability to prevent their data
from being collected and used by Google Analytics. To install Google
Analytics Opt-out Browser Add-on, follow this
link: https://tools.google.com/dlpage/gaoptout?hl=en.
Cloudflare, Inc. The Company uses the services, provided by
Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107 USA.
Сloudflare provides web optimization and security services that the
Company uses to improve and protect the Website, including a reverse
proxy, pass-through security service. Cloudflare may collect the log
data from the visitors of the Website. Additionally, the Company
deployed Cloudflare`s cookie file for security purposes (see Cookies
Policy to find out more). To find out more about the processing of the
data by Cloudflare, please
follow https://www.cloudflare.com/privacypolicy.
Hotjar. Hotjar (registered place of business: Hotjar Ltd, Level 2 St
Julians Business Centre, 3, Elia Zammit Street St Julians STJ 1000,
Malta) is a technology service that helps us better understand our
users’ experience (e.g. how much time they spend on which pages, which
links they choose to click, etc.) and this enables us to maintain, and
improve our Website. Hotjar uses cookies and other technologies to
collect data on our users’ behaviour and their devices (in particular
a device’s IP address (captured and stored only in anonymized form),
device screen size, device type (unique device identifiers), browser
information, geographic location (country only), preferred language
used to display our Website). Hotjar stores this information in a
pseudonymized user profile. If you want to opt-out from the processing
of the data concerning you by Hotjar, please, follow Hotjar`s Opt-out
Webpage via the link https://www.hotjar.com/legal/compliance/opt-out.
We can globally store, access, and facilitate the transfer of Personal
Data. We assess international data transfers and implement appropriate
measures to safeguard your Personal Data in compliance with the
principles defined in this Privacy Notice.
Measure
Description
Adequacy decision
If your Personal Data is transferred to countries outside the European
Economic Area (“EEA”), we ensure the recipient country has received an
adequacy decision from the European Commission. For more information
about adequacy decisions, click here.
Appropriate safeguards
To transfer personal data to recipients lacking an adequacy decision,
we may utilize standard contractual clauses that have been approved by
the European Commission or other legally recognized transfer
mechanisms. For more information about standard contractual clauses,
click here.
In certain circumstances, you have the following data protection
rights:
Your right to access. You have the right to ask us for copies of your
Personal Data.
Your right to rectification. You have the right to have your data
rectified if that data is inaccurate or incomplete.
Your right to erasure. You can request deletion of your Personal Data.
Your right to object. You have the right to object to our processing
of your Personal Data.
Your right to restriction. You have the right to request that we
restrict the processing of your Personal Data.
Your right to data portability. You have the right to be provided with
a copy of the data we have on you in a structured, machine-readable
and commonly used format.
Your right to lodge a complaint. You have the right to lodge a
complaint with a supervisory authority if you believe that we have not
complied with applicable data protection laws.
In order to exercise any of these rights, please contact us using the
following email address: privacy@hitnspin.com
You are not required to pay any charge for exercising your rights. If
you make a request, we have one month to respond to you.
Our Service does not address anyone under the age of 18. We do not knowingly collect Personal Data from anyone under the age of 18.
Cookies are files with small amount of data which are sent to your
browser from a website and stored on your device. Tracking
technologies also used are beacons, tags, and scripts to collect and
track information and to improve and analyze our Service.
Types of Cookies we may use:
Cookie category
Description
Lawful bases
Necessary cookies
These cookies are necessary for allowing users to navigate around our
website and access features.
Necessary for the performance of a contract
Functional cookies
These cookies allow the website to offer enhanced functionality and
personalization. They may be set by us or by third-party providers
whose services we have included on our pages. If you do not allow
these cookies, some or all of these services may not work properly.
Consent (if required under applicable law)
Marketing cookies
These cookies are used to deliver content that is more relevant to you
and your interests. They may be used to deliver targeted
advertisements as well as help measure the effectiveness of an
advertising campaign.
Consent (if required under applicable law)
Performance cookies
To provide functionality to the website and help us deliver our
Services.
Consent (if required under applicable law)
Here is a list of links which will help you to understand how to
manage your cookies preferences:
Information about cookies in general.
How to manage your cookies in Mozilla Firefox.
How to manage your cookies in Chrome.
How to manage your cookies in Safari.
How to manage your cookies in Microsoft Edge.
Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy notice of every site you visit.
We may update this Privacy Notice from time to time. When we update the Privacy Notice, we will revise the “Date published” above and post the new Privacy Notice. We recommend that you review the Privacy Notice each time you visit the Service to stay informed of our privacy practices.