Privacy Policy
Last updated: January 2025
1. Introduction
Winspinaura Oy ("we," "our," "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, process, and safeguard your information in compliance with the EU General Data Protection Regulation (GDPR) and the Finnish Data Protection Act.
2. Data Controller
Winspinaura Oy
PL 105
00101 Helsinki, Finland
Email: privacy@winspinaura.com
3. Data We Collect
3.1 Information You Provide
- Contact Information: Name, email address when you contact us
- Communication Data: Messages, feedback, and support inquiries
- Age Verification: Confirmation that you are 18+ (stored locally)
3.2 Automatically Collected Information
- Technical Data: IP address, browser type, device information
- Usage Data: Pages visited, time spent, interaction patterns (only with consent)
- Cookie Data: As detailed in our Cookie Policy
4. Legal Basis for Processing
We process your personal data based on:
- Consent: For cookies, analytics, and marketing (GDPR Art. 6(1)(a))
- Legitimate Interest: For essential site functionality and security (GDPR Art. 6(1)(f))
- Legal Obligation: For age verification compliance (GDPR Art. 6(1)(c))
5. How We Use Your Data
- Service Provision: To provide and maintain our social casino platform
- Communication: To respond to your inquiries and support requests
- Compliance: To meet legal requirements including age verification
- Analytics: To understand usage patterns and improve our service (with consent)
- Security: To protect against fraud and maintain platform security
6. Consent Management
Where we rely on consent, you have the right to:
- Provide or withdraw consent at any time
- Manage your cookie preferences via our consent panel
- Opt-out of analytics and marketing processing
Non-essential data processors load only after you provide explicit consent.
7. Data Sharing
We do not sell your personal data. We may share data with:
- Service Providers: Third-party analytics and hosting services (with consent)
- Legal Requirements: When required by Finnish or EU law
- Business Transfers: In case of merger or acquisition (you would be notified)
All data sharing is conducted with appropriate safeguards and only as necessary.
8. Data Retention
- Contact Form Data: 2 years from last contact
- Analytics Data: 26 months maximum (industry standard)
- Age Verification: Stored locally on your device only
- Cookie Preferences: 1 year from last update
- Technical Logs: 90 days for security purposes
9. Your Rights Under GDPR
As a data subject, you have the following rights:
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate or incomplete data
- Erasure: Request deletion of your personal data
- Restriction: Limit how we process your data
- Portability: Receive your data in a machine-readable format
- Objection: Object to processing based on legitimate interest
- Withdraw Consent: For consent-based processing
To exercise these rights, contact us at privacy@winspinaura.com. We will respond within 30 days.
10. Data Security
We implement appropriate technical and organizational measures to protect your personal data:
- HTTPS encryption for all data transmission
- Secure hosting with EU-based providers
- Regular security assessments and updates
- Access controls and staff training
- Incident response procedures
11. Children's Privacy
Winspinaura is not intended for individuals under 18. We do not knowingly collect personal data from minors. If we become aware that we have collected data from someone under 18, we will delete it immediately.
12. International Transfers
Your data is primarily processed within the EU/EEA. Any transfers to third countries are conducted with appropriate safeguards such as adequacy decisions or standard contractual clauses.
13. Complaints
If you have concerns about our data processing, you can:
- Contact us directly at privacy@winspinaura.com
- Lodge a complaint with the Finnish Data Protection Ombudsman
- Contact any EU supervisory authority
14. Cookies
For detailed information about our use of cookies and similar technologies, please see our Cookie Policy.
15. Policy Updates
We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated date. Significant changes will be communicated through prominent notice on our website.
16. Contact Information
For privacy-related questions or requests:
Data Protection Contact:
privacy@winspinaura.com
PL 105
00101 Helsinki, Finland