Privacy Policy

This Privacy Policy outlines how gambinoslot, operating via gambinoslotz.com, collects, uses, discloses, and protects personal information. It applies to all players, account holders, and website visitors accessing our services, regardless of their location, and is effective as of 1 January 2025.

Who We Are

Our online gaming services are operated by Spiral Interactive ("Operator"), parent company of gambinoslot, with its principal executive management led by CEO Kobi Samsonov. While our head office functions are based in Israel, we serve users in Australia in full compliance with the Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs). For all privacy inquiries, contact our Data Protection Officer (DPO) at:

Email: [email protected] (General inquiries)
Email: [email protected] (Player support)

What Personal Data We Collect

Personal Identification: Full name, residential address, date of birth, e-mail address, telephone number.
Technical Data: IP address, device identifiers, browser type, operating system, server logs.
Payment Data: Bank account details, credit/debit card information, transaction history.
Behavioural Data: Game play activity, betting history, clickstream data, in-game actions.
Cookies & Similar Technologies: Session cookies, persistent cookies, analytics tracking, advertising pixels.

Legal Basis for Processing

We process your personal data in accordance with the following legal grounds:

Consent: Where you have given explicit consent for specific processing purposes, such as marketing communications.
Contract Fulfilment: Processing necessary to provide services, manage your account, process deposits/withdrawals, and deliver winnings.
Legitimate Interests: Activities necessary for fraud prevention, service optimisation, and ensuring network security, provided these interests do not override your rights.
Legal Obligations: Compliance with applicable laws, including Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) legislation, and responsible gambling requirements.

Purpose of Processing

To provide, maintain, and operate the gambinoslot online casino platform.
To improve service quality and user experience through analytics and feedback.
To send marketing communications where legally permissible and consented.
To detect, prevent, and investigate fraudulent or suspicious activities.
To comply with applicable legal, regulatory, and licensing obligations.

Disclosure & Sharing

Your personal data may be disclosed in the following circumstances:

Payment Partners: Banks, payment gateways, and financial institutions for transaction processing.
Service Providers: IT support, hosting, analytics, and marketing agencies operating under contractual confidentiality.
Regulatory Authorities: Australian Communications and Media Authority (ACMA), AUSTRAC, or other competent bodies as required by law.
Affiliates: Authorised business partners for promotional campaigns, subject to your consent where required.

International Transfers

As part of our global operations, your data may be transferred to countries outside Australia, including Israel, Belarus, and the United States. We ensure that such transfers are protected by appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission, or other legally recognised mechanisms, to maintain the same high level of privacy protection as in Australia.

Data Retention

Player Account Data: Kept for no more than 5 years after account closure, unless retention is required by law.
Transaction Records: Retained for a minimum of 7 years to comply with financial reporting and AML/CTF legislation.
Marketing Data: Retained until you withdraw your consent or opt out of communications.

When retention periods expire, data is securely deleted or anonymised.

Your Rights

Subject to applicable law, you have the right to:

Access the personal data we hold about you.
Request correction of inaccurate or incomplete data.
Request erasure of personal data, subject to legal and contractual limitations.
Restrict or object to processing in certain circumstances.
Request data portability to another service provider in a structured, machine-readable format.
Withdraw consent for marketing communications at any time.

Cookies & Tracking Technologies

Session Cookies: Temporary cookies essential for website operation, deleted after browser closure.
Persistent Cookies: Remain on your device to remember preferences and improve functionality.
Third-Party Cookies: Set by analytics providers and advertising networks for performance measurement and personalised offers.

You can manage cookies through your browser settings or opt-out tools. Disabling cookies may affect site functionality.

Data Security

We implement technical and organisational measures to protect your data:

SSL encryption for data transmission.
Encryption of stored sensitive information.
Restricted staff access on a need-to-know basis.
Regular security audits and penetration testing.
Staff training on data protection and privacy compliance.

Complaints & Contacts

For privacy-related questions or complaints, you may contact our DPO at [email protected]. We will investigate all complaints and respond within a reasonable timeframe. If you are unsatisfied with our response, you may escalate the matter to the Office of the Australian Information Commissioner (OAIC).

Updates

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Updates will be posted on gambinoslotz.com with a revised "Effective Date". Last reviewed: 1 January 2025.