Privacy Policy

Who We Are

The website  is owned and operated by Hollycorn N.V. (reg. No. 144359, Heelsumstraat 51, E-Commerce Park, Curaçao). We act as the data controller and process players’ personal data to provide gaming services and comply with legal requirements.
Our DPO: [email protected]. Support: [email protected], live chat.

Who This Site Is For

Services are intended for 18+ only. If we discover data relating to minors, we will act in accordance with the law and remove such records.

Key Terms (Brief)

• Personal data: any information about an identified or identifiable natural person.

• Processing: any operation performed on data, from collection to deletion.

• Profiling: automated analysis used to assess user behavior.

• Controller/processor/recipient/third party — as defined in the GDPR.

• Personal data breach: unauthorized loss, access, or disclosure of information.

Data We Collect

1. Provided by you: name, date of birth, country, address, email and phone, username, KYC documents (ID, proof of address/source of funds), payment details.

2. Technical: IP, browser type/version, time zone, OS, cookies, URL paths.

3. Gaming & transactional: deposits/withdrawals, bets, games and session duration, bonuses, RG/AML status.

4. Analytics: on-site actions, logs, timestamps, events.

5. From other sources: age/identity verification providers, sanctions and PEP checks, regulators, affiliated group sites.

6. Special categories (only if you provide them and where required by law): Responsible Gaming information, attributes inferred from documents (e.g., ethnic origin that might indirectly appear in an ID).

How and Why We Use Data

• Service delivery: account creation, deposits, payouts, support, complaint handling.

• Legal compliance: AML/CTF checks, KYC, license requirements.

• Security & fraud prevention: risk profiles, bonus-abuse detection, protection against VPN/proxy abuse.

• Responsible Gaming: assessing gambling-harm risks, possible RG scoring and protective measures.

• Marketing: promotions for our brands and partners with your consent or under legitimate interests (you can opt out anytime in your profile or via support).

• Personalization & analytics: tailoring content, measuring ad effectiveness, improving the site.

• Aggregated reports: anonymized statistics without identifying individuals.

For some purposes, we use profiling with human review of outcomes. Detailed logic is not disclosed to prevent circumvention of our controls.

Legal Bases

• Contract: registration, payments, access to games.

• Legal obligation: AML/KYC, tax and regulatory duties.

• Legitimate interests: security, fraud prevention, analytics, internal operations.

• Consent: third-party marketing, certain cookies and personalization.

Marketing & Preferences

Manage your consents in your profile spinrise.com/user or contact support/Live Chat. Opting out does not affect the lawfulness of past processing.

Who We May Share Data With

• Group companies (service delivery, AML/RG, fraud prevention).

• Employees under NDAs (support, VIP, finance, AML/fraud analysts, DPO, etc.).

• Game providers and payment processors (minimum necessary attributes).

• Marketing vendors (email/SMS/calls with your consent).

• Regulators, courts, law enforcement where required by law.

• Lawyers, advisors, KYC/AML tools, client-communication software.

• Business reorganization scenarios — with prior notice to users.
  Third parties act on our instructions and may not use data for their own purposes.

International Transfers

Data may be processed outside the EU/EEA for payments, gaming, and checks. We use EU Standard Contractual Clauses and other safeguards to protect your data.

Retention

We keep data only as long as necessary for collection purposes and legal requirements. Due to EU AML rules, player data are retained for at least 5 years after the last transaction/account closure. We may use anonymized derivatives for content and marketing without automated decision-making.

Your Rights

You can:

• Access your data.

• Rectify inaccuracies (we may request proof).

• Erase data when no legal basis for further processing exists.

• Object to processing based on legitimate interests.

• Restrict processing in GDPR-defined cases.

• Port data you provided that we process automatically under consent/contract.

• Withdraw consent at any time (does not affect prior processing).

• Lodge a complaint with a supervisory authority.

We may request identity verification. We usually respond within 1 month; complex cases may take longer with notice.

Automated Decisions

We generally do not make decisions solely by automated means. If we do in individual cases, we will inform you where legally required.

Security

We apply technical and organizational safeguards, limit staff access, and support 2FA. You are responsible for keeping your login credentials confidential.

Contact Us

• General inquiries & support: [email protected] or Live Chat.

• DPO, privacy complaints, delayed responses, copies of data: [email protected].
  If you receive no reply within 10 days, please resend via an alternative channel.

Policy Updates

We may update this policy periodically. Continued use of the Site signifies acceptance of the current version. Please review it from time to time.