This Privacy Policy explains how RoyalSpinia Casino, operated by Tekuno Technologies S.R.L. at royalspiniaapp.nl, collects, uses, stores, shares, and protects your personal data. By registering an account or using our services, you acknowledge that you have read and understood this policy. We are committed to handling your information responsibly and in compliance with applicable data protection legislation and the requirements of our licence issued by the Tobique Gaming Commission.

1. Who We Are

RoyalSpinia Casino is operated by Tekuno Technologies S.R.L., the data controller responsible for personal data processed through royalspiniaapp.nl. References to "RoyalSpinia", "we", "us", or "our" throughout this document refer to Tekuno Technologies S.R.L. in its capacity as operator of the RoyalSpinia brand. If you have any questions about how your data is handled, you may contact us via live chat (available 24/7) or by email through the address provided in the Contact section at the foot of this policy.

2. What Data We Collect

We collect personal data at different points during your relationship with us. The categories of data we may hold about you include the following.

2.1 Registration and Identity Data

• Full name
• Date of birth
• Residential address
• Email address
• Telephone number
• Username and encrypted password
• Nationality and country of residence

2.2 Identity Verification (KYC) Data

As a licensed operator under the Tobique Gaming Commission, we are legally obliged to verify the identity of our players before processing withdrawals and, in certain circumstances, before accepting deposits beyond defined thresholds. Documents we may request include:

• Government-issued photo identification (passport, national identity card, or driving licence)
• Proof of address (utility bill, bank statement, or official correspondence dated within the last three months)
• Proof of payment method (front-of-card images, screenshots of e-wallet accounts, or cryptocurrency wallet confirmation)
• Source-of-funds or source-of-wealth documentation where required by our regulatory obligations or internal risk procedures
• Selfie or liveness check, where requested to confirm document authenticity

2.3 Financial and Transaction Data

• Deposit and withdrawal amounts, methods, and timestamps
• Payment method identifiers (masked card numbers, e-wallet account references, cryptocurrency wallet addresses)
• Transaction histories including bonuses credited, cashback applied, and rakeback paid
• Withdrawal limits applied to your account, whether standard (€3,000 weekly / €10,000 monthly) or personalised VIP arrangements

2.4 Gaming Activity Data

• Games played, wagers placed, wins and losses
• Session durations and login timestamps
• Bonus and promotion participation, including free spin usage, Wheel of Fortune entries, tournament results, and Spinoleague activity
• VIP tier status (Bronze, Silver, Gold, or Platinum) and loyalty points balance
• Sportsbook betting history

2.5 Technical and Device Data

• IP address
• Device type, operating system, and browser version
• Progressive Web App (PWA) installation data where applicable
• Cookies and similar tracking technologies (see Section 9)
• Geolocation data (country or region level, derived from IP address)
• Platform interaction logs and clickstream data

2.6 Communications Data

• Records of live chat conversations with our support team
• Email correspondence
• Responsible gaming communications, including self-exclusion requests, deposit limit settings, and cooling-off requests

3. How We Collect Your Data

We collect personal data through the following means:

• Directly from you — when you register, complete KYC verification, make deposits or withdrawals, contact support, or participate in promotions
• Automatically — through cookies, server logs, and platform analytics tools as you browse and play on royalspiniaapp.nl or via the PWA
• From third parties — including identity verification providers, payment processors (such as those facilitating Visa, Mastercard, Skrill, Neteller, or cryptocurrency transactions), fraud prevention agencies, and our gaming software providers where necessary for service delivery

4. Why We Use Your Data — Legal Bases and Purposes

We process your personal data only where we have a lawful basis for doing so. The table below sets out our principal processing purposes and the corresponding legal basis.

5. Identity Verification and KYC

RoyalSpinia operates under a Tobique Gaming Commission licence, which imposes mandatory know-your-customer (KYC) obligations. We cannot process withdrawal requests until satisfactory verification has been completed. We may also require verification before a deposit is accepted if our risk monitoring systems flag a concern.

You will be asked to submit KYC documentation promptly when requested. Failure to provide adequate documentation within a reasonable timeframe may result in a temporary hold on your account or the suspension of withdrawal processing until compliance is achieved. All documents submitted are handled securely, stored only for as long as legally required, and accessed only by authorised personnel on a need-to-know basis.

We use TLS 1.3 encryption for all data in transit, and document files are stored using industry-standard security controls. Our backend threat-monitoring systems operate continuously to detect unauthorised access attempts.

6. Sharing Your Data

We do not sell your personal data. We may share your data with third parties only in the circumstances described below.

6.1 Service Providers and Data Processors

We engage third-party companies to help us deliver our services. These processors act only on our documented instructions and are bound by data processing agreements. Categories of processor include:

• Payment processors and acquiring banks facilitating transactions via Visa, Mastercard, Skrill, Neteller, bank transfer, and cryptocurrency networks (BTC, ETH, LTC, TRON)
• Identity verification and KYC service providers
• Anti-fraud and threat-monitoring technology providers
• Gaming software suppliers, including game studios such as BGaming, Pragmatic Play, NetEnt, Play'n GO, Evolution, LuckyStreak, and others whose titles appear in our lobby, where data sharing is technically necessary to deliver game sessions
• Customer support platform providers
• Email and communications infrastructure providers
• Analytics and platform performance providers

6.2 Regulatory and Legal Authorities

We may disclose personal data to the Tobique Gaming Commission, law enforcement agencies, tax authorities, or other competent authorities where we are legally required or permitted to do so. This includes disclosures made in connection with anti-money-laundering investigations, fraud prevention, or court orders.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of our business, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you of any such change and ensure equivalent protections apply.

6.4 With Your Consent

Where we wish to share your data for purposes not described in this policy, we will seek your explicit consent before doing so.

7. International Data Transfers

Tekuno Technologies S.R.L. and some of our third-party service providers may be located in, or process data in, jurisdictions outside the European Economic Area. Where such transfers occur, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by competent supervisory authorities or equivalent transfer mechanisms, to protect your data to an equivalent standard as required under applicable law.

8. Data Retention

We retain your personal data for as long as is necessary to fulfil the purposes described in this policy and to comply with our legal obligations. As a general guide:

• Account data is retained for the duration of your account and for a minimum of five years after account closure, in line with anti-money-laundering regulatory requirements
• KYC documents are retained for at least five years from the end of the customer relationship, or longer if required by applicable law or regulatory instruction
• Transaction records are retained for at least five years for financial crime compliance purposes
• Communications records (live chat, email) are retained for the period necessary to resolve the relevant enquiry and for a reasonable period thereafter for audit and dispute-resolution purposes
• Marketing consent records are retained for as long as you have an active marketing preference or until you withdraw consent, plus a reasonable period to demonstrate compliance

When data is no longer required, it is securely deleted or anonymised.

9. Cookies and Tracking Technologies

royalspiniaapp.nl uses cookies and similar technologies to operate the platform, remember your preferences, analyse usage, and deliver relevant promotional content. The principal categories of cookie we use are as follows:

When you first visit royalspiniaapp.nl you will be presented with a cookie consent notice. You may adjust your non-essential cookie preferences at any time through the cookie settings tool on the site. Please note that disabling certain cookies may affect the functionality of some platform features. Your browser settings may also allow you to block or delete cookies independently; consult your browser's help documentation for guidance.

10. Marketing Communications

Where you have given your consent, we may send you emails or in-platform messages about bonuses, promotions, new game releases, VIP tier updates, and other features available at RoyalSpinia. Examples of communications you may receive include information about the Welcome Bonus (up to €1,500 + 250 Free Spins), Sunday Reload offers, Weekly Cashback percentages, the Highroller Bonus, Wheel of Fortune entries, live tournaments, and the Spinoleague prize pool.

You may withdraw your consent to marketing communications at any time by:

• Clicking the unsubscribe link at the foot of any marketing email
• Updating your communication preferences in your account Profile
• Contacting our support team via live chat or email

Withdrawing consent to marketing will not affect the lawfulness of processing carried out before withdrawal, and will not affect the delivery of transactional messages necessary for the management of your account.

11. Responsible Gaming and Data

RoyalSpinia is committed to promoting responsible gaming. To this end, we process certain data specifically to protect players from gambling-related harm. This includes:

• Recording and enforcing deposit limits, session time limits, loss limits, and wagering limits that you set in your account
• Processing and honouring cooling-off and self-exclusion requests, and maintaining exclusion records for the duration required to prevent accidental re-registration
• Monitoring gaming activity patterns that may indicate signs of problem gambling, enabling us to intervene proactively where appropriate
• Sharing data with responsible gaming and self-exclusion schemes where we are required or permitted to do so under our licensing obligations

Responsible gaming data is treated with particular sensitivity and accessed only by staff with a legitimate need to do so. If you wish to access, correct, or discuss the responsible gaming data held on your account, please contact our support team.

12. Security

We take the security of your personal data seriously. Measures in place at RoyalSpinia include:

• TLS 1.3 encryption for all data transmitted between your device and royalspiniaapp.nl
• Backend threat-monitoring systems that flag unusual activity in real time
• Encrypted storage of sensitive data including passwords and payment method references
• Access controls limiting data access to authorised personnel on a role-based, need-to-know basis
• Regular security assessments of our platform and third-party integrations

Despite these measures, no system is entirely infallible. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, you as an affected individual, in accordance with applicable law.

You also have a role in keeping your account secure. Please use a strong, unique password, do not share your login credentials, and contact us immediately via live chat or email if you suspect any unauthorised access to your account.

13. Your Rights

Depending on your jurisdiction and applicable law, you may have the following rights in relation to your personal data held by RoyalSpinia:

• Right of access — to request a copy of the personal data we hold about you
• Right to rectification — to ask us to correct inaccurate or incomplete data
• Right to erasure — to request deletion of your data where we no longer have a lawful basis to retain it (subject to overriding legal obligations such as AML record-keeping requirements)
• Right to restriction of processing — to ask us to pause processing of your data in certain circumstances
• Right to data portability — to receive a copy of data you have provided to us in a structured, machine-readable format, where processing is based on consent or contract and is carried out by automated means
• Right to object — to object to processing carried out on the basis of our legitimate interests, including direct marketing
• Right to withdraw consent — where processing is based on your consent, to withdraw that consent at any time without affecting the lawfulness of prior processing
• Rights related to automated decision-making — not to be subject to a decision based solely on automated processing that produces significant legal or similarly significant effects, without human review

To exercise any of these rights, please contact us via live chat or email. We will respond within the timeframe required by applicable law. We may need to verify your identity before fulfilling a request. In certain circumstances we may be unable to comply with a request — for example, where retention is required by law — and we will explain our reasons if this is the case.

14. Automated Decision-Making and Profiling

We use automated systems to support certain decisions on our platform. For example, our fraud-detection and threat-monitoring tools may automatically flag or temporarily restrict an account where unusual activity is detected. Our responsible gaming monitoring tools may trigger automated alerts based on changes in your gaming behaviour. Where a consequential decision is made solely by automated means, you have the right to request human review. Please contact our support team to exercise this right.

We also use profiling to personalise your experience — for example, to determine which promotional offers may be relevant to you based on your VIP tier, play history, or preferred game categories. You may object to marketing profiling at any time as set out in Section 10.

15. Third-Party Links and Platforms

royalspiniaapp.nl may contain links to third-party websites or integrations with third-party game providers and payment services. This Privacy Policy applies solely to data processed by RoyalSpinia. Third-party services have their own privacy policies, and we encourage you to read them before sharing your data with those parties. We are not responsible for the privacy practices of any third-party site or service.

16. Children

RoyalSpinia is strictly for adults. Our services are not directed at, and must not be used by, any person under the age of 18. We do not knowingly collect personal data from anyone under 18. If we become aware that a minor has provided us with personal data or has opened an account, we will close the account, void any balances, and delete the data as soon as reasonably practicable. If you believe a minor has registered with us, please notify us immediately via live chat or email.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or the services we offer. When we make material changes, we will notify you by posting a prominent notice on royalspiniaapp.nl and, where appropriate, by sending you a direct communication. The date of the most recent revision will always be shown at the top of this page. Your continued use of RoyalSpinia following notification of changes constitutes your acknowledgement of the updated policy.

18. How to Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or the way we handle your personal data, please contact us using the details below:

• Live chat: Available 24/7 via royalspiniaapp.nl
• Email: Available via the contact form or support email address listed on royalspiniaapp.nl
• Operator: Tekuno Technologies S.R.L.
• Website: royalspiniaapp.nl

We will endeavour to resolve your query promptly and fairly. If you are not satisfied with our response, you may have the right to lodge a complaint with the data protection supervisory authority in your country of residence.