Privacy Policy

This privacy policy is effective from 12th June 2019. All previous privacy policies are cancelled and replaced with this privacy policy.

This privacy policy applies to the entire contents of this website and other websites including applications operated by Fairdos Online Services Limited, including without limitation www.spin247.com.

Fairdos Online Services Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Fairdos Online Services Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you register an account, make a deposit, play any of our games or take part in a competition or promotion.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on future specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.

CONTROLLER

Fairdos Online Services Limited is the controller and responsible for your personal data (collectively referred to as “Fairdos Online Services Limited”, “we”, “us” or “our” in this privacy policy).

Our Legal Department is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Legal Department in writing using the details set out below.

You have the right to make a complaint at any time to the Office of the Commissioner for Personal Data Protection, accessed here: http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/home_el/home_el?opendocument

We would, however, appreciate the chance to deal with your concerns before you approach the Office of the Commissioner for Personal Data Protection so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
Contact Data includes billing address, delivery address, email address and telephone numbers;
Financial Data includes bank account, payment card details Mobile billing and PayPal and Skrill transactions;
Transaction Data includes details about payments to and from you.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;
Profile Data includes your username and password, deposit methods made by you, your interests, preferences, feedback and survey responses;
Usage Data includes information about how you use our website and games.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Due to our regulatory requirements we will collect information about criminal convictions and offences as part of our PEP and sanction procedures, however, this information will not be passed to third parties unless required by law.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with gambling services). In this case, we may have to close your account you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your identity, contact and financial data by logging in to your account, filling in forms or by corresponding with us by post, phone, email, live chat or otherwise. This includes personal data you provide when you:
Register an account;
Contact us by telephone, email or live support facility;
Request marketing to be sent to you;
Enter a competition, promotion or survey; or
Give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

(a)analytics providers such as Google based outside the EU;

(b)search information providers based inside the EU such as:

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Fonix based inside the EU.
Identity and Contact Data from data brokers or aggregators such as GB Group based inside the EU.
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Enable us to set up your account so that you can make full use of all of the features of the services, including crediting your account with funds, and playing games;
Comply with relevant regulations regarding your registration for example completing age verification checks; and
(provided that you do not opt out of receiving marketing materials), to keep you informed of future events, offers and promotions from us (and any other company in our group);
Setting up, operating and managing your account;
Providing any of the services which are requested of us, and for any proper purpose connected with such provision;
Verifying the accuracy of your information, including disclosure of such information to third parties (including financial institutions, age verification and credit reporting agencies);
Preparing statistics, providing analytical reports and analysis relating to the use of the services by you and other customers;
Analysing and recording your use of services and websites in order to improve our products and the way we deliver the services;
Preparing and displaying appropriate individualised marketing material and content;
Conforming to regulatory and legal requirements or complying with legal processes;
The investigation of suspected unlawful, fraudulent or other improper activity connected with the services;
The reporting of a crime or suspected crime, including money laundering, proceeds of crime or any fraud; and
Any other purpose which is necessary for the performance of our contractual obligations to you or our legal and regulatory obligations;

You have the right to withdraw consent to marketing at any time by:

telephone live chat, via the Support Button on the Website; or
using the unsubscribe feature in the marketing material.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.


	
		
			Purpose/Activity
			Type of data
			Lawful basis for processing including basis of legitimate interest
		
		
			To register you as a new customer and choose whether to give explicit consent or not to receiving free bonuses and exclusive offer news from Fairdos Online Services Limited.
			(a) Identity
 (b) Contact
(c) Marketing and Communications
			Performance of a contract with you; Processing and disclosure of your Personal Information for the purposes of sending relevant marketing material, promotions and prizes to you.
		
		
			To process and deliver your transactions including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
			(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
			(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
		
		
			To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
			(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
			(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
		
		
			To enable you to partake in a prize draw, promotion, competition or complete a survey
			(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
			(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
		
		
			To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
			(a) Identity
(b) Contact
(c) Technical
			(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
		
		
			To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
			(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
			Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
		
		
			To use data analytics to improve our website, services, marketing, customer relationships and experiences and Responsible Gambling requirements
			(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Technical
(f) Usage
			Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy and to ensure we comply with our Social and Responsibility Requirements)
		
		
			To make suggestions and recommendations to you about our new games, promotions and depositing methods that may be of interest to you
			(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
			Necessary for our legitimate interests (to develop our services and grow our business)

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer and choose whether to give explicit consent or not to receiving free bonuses and exclusive offer news from Fairdos Online Services Limited.	(a) Identity (b) Contact (c) Marketing and Communications	Performance of a contract with you; Processing and disclosure of your Personal Information for the purposes of sending relevant marketing material, promotions and prizes to you.
To process and deliver your transactions including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To enable you to partake in a prize draw, promotion, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences and Responsible Gambling requirements	(a) Identity (b) Contact (c) Profile (d) Usage (e) Technical (f) Usage	Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy and to ensure we comply with our Social and Responsibility Requirements)
To make suggestions and recommendations to you about our new games, promotions and depositing methods that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our services and grow our business)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not agreed to receive that marketing.

Where you have agreed to receive such communications, Fairdos Online Services Limited may use contact you for marketing purposes by SMS, email or phone. These marketing messages will provide you with various information about our new games, promotions and other services.

We may also send push notifications to your mobile device in order to provide game updates, account communications, promotions or other relevant messages.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the Fairdos Online Services Limited group of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.

Cookie Policy

INTRODUCTION

This Cookie Policy details what cookies are installed on this website. This policy is relevant to anyone browsing this website and using our services. We would recommend that all users of this website read this policy.

Please note that this cookie policy applies to users who are browsing our websites on a mobile device, including but not limited to: smartphone, tablets and any other electronic device that has the capacity to provide internet access.

CHANGES AND UPDATES TO THIS POLICY

From time to time we may amend this cookie policy to fall in line with changes in legislation, including from not limited to the General Data Protection Regulation 2016, the Privacy and Electronic Communication Regulation 2016 and the Data Protection Act 2018. We may also amend or modify this cookie policy when new functionalities or content are added to our websites.

Any updates or changes to this Cookie Policy will be mentioned below.

Last update: 17/01/2019

WHAT IS A “COOKIE”?

A “cookie” is a small text file that is downloaded onto your access device when you visit a Website and that enables the website to obtain certain information from your browser which includes your preferences. All Websites which are operated by Fairdos Online Services Limited use cookies and similar technologies to manage login sessions, provide personalized web pages to tailor advertising and other content to reflect your specific needs and interests. A cookie does not harm your access device nor does it contain any viruses or other malware.

There are two main types of cookies used on website across the internet:

Persistent cookie which is stored on a user’s device from the first visit of the website
Non-persistent cookie (also known as a session cookie) are only in use for the duration of the internet session. Non-persistent cookie is never stored on a user’s device

Within the above types of cookies, there are several kind of cookies as listed below:

Cookies that are “strictly necessary” for the website to work properly and offer basic browsing functionalities. Without those cookies, the website would not function properly and it would be impossible to browse it and navigate through the different section.
“Performance” cookies which collect basic information about how the website is used and which web pages are visited. Performance cookies also collect general information about the user’s device (such as IP address, browser versions etc). The data collected is anonymous and is used for analytical purposes to improve the services we provide
“Functionality” cookies which allow the websites to remember choices you make and your preferences as a logged-in user
“Targeting or advertising” cookies which are used to deliver relevant adverts to specific devices for a more tailored user experience

The cookies that are used on our websites do not collect any personally identifiable information from the website usage. The technical data that is collected is used for analytical purposes. This data helps us understand how we can enhance the browsing experience by providing more suitable content to the users of the website.

All of the following cookies are currently in use on the website:

Cookie Name
Purpose
Persistent or Session

ANON
This cookie is associated with Bing. This specific cookie is used for site analytics and advertising purposes.
Expires after 6 months

MUID
This cookie is associated with Bing. This specific cookie is used f or site analytics and advertising purposes.
Expires after 1 year

MUIDB
This cookie is associated with Bing. This specific cookie is used f or site analytics and advertising purposes.
Expires after 1 years

NAP
This cookie is associated with Bing. This specific cookie is used for site analytics and advertising purposes
Expires after 6 months

1P_JAR
This cookie is related to Google Analytics and it is used for analytics purposes
Expires after 1 month

CONSENT
This cookie records user consent once the cookie policy has been accepted
Expires after 20 years

NID
This cookie is used to remember user preferences in regards to the use of the website. This cookie is associated with Google Analytics
Expires after 6 months

Datr
This cookie is related to Facebook, its purposes is to understand what web session accessed the social media network
Expires after 2 years

Fr
This cookie is related to Facebook, its purposes is to allocate an encrypted browser ID and Facebook ID for advertisement purposes
Expires after 3 months

sb
This cookie is related to Facebook, its purposes is to improve friends suggestion with the social network platform
Expires after 2 years

OTZ
This cookie is associated with Google Analytics. It collects anonymous information with regards to the way this website is used. This data is then used for analytical purposes
Expires after 1 month

__cfduid
This cookie is related to Cloudflare (website cyber security solutions provider)
Expires after 1 year

_ga
Performance cookie used for website analytics. This cookie is associated with Google Universal Analytics
Expires after 2 years

_gat
Performance cookie used for website analytics. This cookie is associated with Google Universal Analytics
Expires at the end of the session

_gid
Performance cookie used for website analytics. This cookie is associated with Google Universal Analytics
Expires after 24 hours

vid
This cookie is a first party cookie. It allows us to keep track of the logged in entity using the website
Expires after 1 year

PREF
This cookie is set by Youtube. The purpose of this cookie is to keep track of user preferences and serve up related content within an embedded video player
Expires after 8 months

VISITOR_INFO1_LIVE
This cookie is set by Youtube. The purpose of this cookie is to measure the bandwidth available on the user’s browser to determine what version of the youtube player is used
Expires after 6 months

Cookie Name	Purpose	Persistent or Session
ANON	This cookie is associated with Bing. This specific cookie is used for site analytics and advertising purposes.	Expires after 6 months
MUID	This cookie is associated with Bing. This specific cookie is used f or site analytics and advertising purposes.	Expires after 1 year
MUIDB	This cookie is associated with Bing. This specific cookie is used f or site analytics and advertising purposes.	Expires after 1 years
NAP	This cookie is associated with Bing. This specific cookie is used for site analytics and advertising purposes	Expires after 6 months
1P_JAR	This cookie is related to Google Analytics and it is used for analytics purposes	Expires after 1 month
CONSENT	This cookie records user consent once the cookie policy has been accepted	Expires after 20 years
NID	This cookie is used to remember user preferences in regards to the use of the website. This cookie is associated with Google Analytics	Expires after 6 months
Datr	This cookie is related to Facebook, its purposes is to understand what web session accessed the social media network	Expires after 2 years
Fr	This cookie is related to Facebook, its purposes is to allocate an encrypted browser ID and Facebook ID for advertisement purposes	Expires after 3 months
sb	This cookie is related to Facebook, its purposes is to improve friends suggestion with the social network platform	Expires after 2 years
OTZ	This cookie is associated with Google Analytics. It collects anonymous information with regards to the way this website is used. This data is then used for analytical purposes	Expires after 1 month
__cfduid	This cookie is related to Cloudflare (website cyber security solutions provider)	Expires after 1 year
_ga	Performance cookie used for website analytics. This cookie is associated with Google Universal Analytics	Expires after 2 years
_gat	Performance cookie used for website analytics. This cookie is associated with Google Universal Analytics	Expires at the end of the session
_gid	Performance cookie used for website analytics. This cookie is associated with Google Universal Analytics	Expires after 24 hours
vid	This cookie is a first party cookie. It allows us to keep track of the logged in entity using the website	Expires after 1 year
PREF	This cookie is set by Youtube. The purpose of this cookie is to keep track of user preferences and serve up related content within an embedded video player	Expires after 8 months
VISITOR_INFO1_LIVE	This cookie is set by Youtube. The purpose of this cookie is to measure the bandwidth available on the user’s browser to determine what version of the youtube player is used	Expires after 6 months

WHAT INFORMATION IS GATHERED?

The data gathered revolves around the way the users interact with the website during their visit. This includes: what pages and sections of the website are visited, what links are being clicked on, how many users are currently logged in, whether or not content is being shared on social media. As mentioned previously, this data is purely technical and it does not allow us to identify an individual.

This website uses an analytical tool that is provided by Google Analytics. We would recommend that you read Google’s privacy policy. Please refer to the following links for more information with regards to the way Google processes your data: https://policies.google.com/privacy

CONSENT FOR COOKIES

Any strictly necessary cookies that are in use on this website will not give the ability to opt-out. If you wish to opt-out of third party cookies, please refer to the following section. A pop up banner will appear on your first visit to this website to inform you about cookies and prompt you whether or not you agree. If you do not agree with cookies, please refer to the following sections.

HOW TO OPT OUT?

To opt out of Google Analytics cookies, visit the following link. All the information required to opt out of Google Analytics are detailed: http://tools.google.com/dlpage/gaoptout

HOW TO DELETE THE COOKIES THAT ARE STORED ON YOUR MACHINE?

If you want to delete the cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. You can also access them through your internet browser.

ADDITIONAL INFORMATION ABOUT COOKIES

Please refer to the following page for general information about cookies and guidance on how to delete cookies that are stored on your machine: https://www.aboutcookies.org/

Please refer to the following page for more information about Google Analytics: https://www.google.com/analytics/#?modal_active=none

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Where required by law, your personal information may also be disclosed to an applicable governmental, regulatory or enforcement authority. Additionally, in circumstances where we deem it appropriate, your personal information may be disclosed to any regulatory authority which has issued any company within the with a gambling operator licence.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We share your personal data within the Fairdos Online Services Limited Group. This may involve transferring some of your data outside the European Economic Area (EEA). has offices located in Romania (EEA) and in Taiwan (outside the EEA).

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we will ensure personal data has a similar degree of protection that it would have in Europe.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

All data on our secure websites is encrypted using Transport Layer Security (TLS) technology. Where we have given you (or where you have chosen) a password which enables you to access your account, you are responsible for keeping this password confidential.

Any data which contains personal information which identifies you will be encrypted at all times whilst in transit over the internet. TLS is a special protocol that automatically encrypts any information sent by you on our secure pages. Our server then reads the information using a private key. This means that your information, be it debit or credit card information or any other personal details, is turned into code that can only be decoded with the private key or password.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law to maintain our compliance with AML regulations we are required to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a period of at least five years after the relationship with the customer has ended. The date the relationship with the customer ends is the last date on which they visit or use our services.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Should you wish to make a Subject Access Request you should contact us in writing at:

Subject Access Request c/o Legal Department, Achilleos, 21 Flat/Office B, Agios Dometios 2370, Nicosia, Cyprus

Or via email at: complaints@spin247.com

You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request.

However, a request can be refused if it is ‘manifestly unfounded or excessive’. An example of a request that may be excessive is one that merely repeats the substance of previous requests. We must notify you in writing, and without undue delay, if your request has been refused and this will contain the reasons for refusal.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.