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Privacy Policy | Highspinn Ireland
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Privacy Policy

At Highspinn, operating on the robust G4Casino infrastructure, the safeguarding of your data is our paramount operational directive. This comprehensive Privacy Policy outlines our data acquisition parameters, processing frameworks, cryptographic mitigation strategies, and your statutory rights as a user operating within the Republic of Ireland and the broader European Economic Area (EEA) under the General Data Protection Regulation (GDPR).

1. Introduction and Data Controller Designation

Highspinn Ireland ("we", "us", or "our") respects your privacy and is fundamentally committed to protecting your personal data. This privacy notice informs you as to how we look after your personal data when you visit our platform (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you. For the purposes of the GDPR, Highspinn acts as the primary Data Controller. This means we are responsible for deciding how we hold and use personal information about you. We have appointed a dedicated Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice.

2. Categorization of Personal Data Acquired

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). To provide you with our premium iGaming services, we systematically collect, use, store, and transfer different kinds of personal data 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. Furthermore, for KYC (Know Your Customer) compliance, this includes photographic identification, passports, or national ID cards.
  • Contact Data: Includes billing address, residential address, email address, and telephone numbers.
  • Financial Data: Includes bank account and payment card details utilized across our Payment Service Provider (PSP) network. Please note that Highspinn does not natively store full credit card hashes; these are tokenized via PCI DSS Level 1 compliant gateways.
  • Transaction Data: Includes details about fiat or cryptocurrency payments to and from you, withdrawal requests, wager history, active bonuses, and other details of products and services you have purchased from us.
  • Technical & Telemetry 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 Optical Character Recognition (OCR) interactions within our Live Casino environments.
  • Usage Data: Includes information about how you navigate our website, the duration of your sessions, the specific RNG slots or bingo lobbies accessed, and your interaction with promotional pipelines.
  • Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties, as well as your communication preferences.

3. Mechanisms of Data Acquisition

We use different methods to collect data from and about you, ensuring that our data acquisition strategies are both transparent and legally compliant. These methods include:

Direct Interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or live chat. This includes personal data you provide when you create an account, claim a 120% deposit bonus, request marketing to be sent to you, or contact customer support.

Automated Technologies or Interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using modular tracking technologies, server logs, and other similar analytical tools. Please see our Cookie Policy for further granular details.

Third Parties or Publicly Available Sources: We will receive personal data about you from various third parties and public sources, specifically identity and contact data from fraud prevention agencies, KYC auditors, and AML screening networks based inside and outside the EU.

4. Purposes and Lawful Basis for Processing

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:

  • Performance of a Contract: Where we need to perform the contract we are about to enter into or have entered into with you (i.e., providing you access to our gaming platform and executing your wagers).
  • Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., to prevent fraud, optimize our UI/UX, and ensure network security).
  • Legal Obligation: Where we need to comply with a legal obligation, specifically Anti-Money Laundering (AML) directives, the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 in Ireland, and directives established by the Revenue Commissioners.

5. Data Security Frameworks and Cryptography

The security of your capital and data is absolute. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. All data transmitted between your local node and our servers is secured via TLS 1.3 cryptographic handshakes. Furthermore, your data is siloed behind enterprise-grade firewalls.

We limit access to your personal data to those employees, agents, contractors, and other third parties who have a strict operational "need to know." They will only process your personal data on our instructions, and they are subject to strict Non-Disclosure Agreements (NDAs). 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.

6. International Data Transfers

To deliver our premium services, it is sometimes necessary for us to share your personal data with external third parties based outside the European Economic Area (EEA) (e.g., certain software providers or server hosts). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. Where we use certain service providers, we may use specific contracts approved by the European Commission (Standard Contractual Clauses) which give personal data the same protection it has in Europe.

7. Data Retention Policies

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for five to seven years after they cease being customers for tax and AML compliance purposes. In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Your Statutory Legal Rights

Under certain circumstances, you have rights under GDPR data protection laws in relation to your personal data. These rights include:

  • Request Access (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: This enables you to have any incomplete or inaccurate data we hold about you corrected.
  • Request Erasure (Right to be Forgotten): This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note that AML and regulatory retention laws often supersede erasure requests.
  • Object to Processing: You have the absolute right to object where we are processing your personal data for direct marketing purposes.
  • Request Restriction of Processing: This enables you to ask us to suspend the processing of your personal data in specific scenarios.
  • Request Data Portability: We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

9. Implementation of Responsible Gaming Telemetry

In alignment with our Responsible Gaming directives, we monitor Usage Data and Transaction Data to identify potentially harmful gambling behaviors. This processing relies on both legal obligations to provide a safe environment and our legitimate interest in protecting our user base. We utilize internal algorithms that may automatically suggest limits or trigger interventions based on erratic deposit patterns or extended session durations. This data is fiercely protected and never utilized for aggressive marketing profiling.

10. Contacting the Data Protection Officer

If you have any questions about this privacy notice or our privacy practices, including any requests to exercise your legal rights, please contact our DPO using the support infrastructure provided in the Highspinn lobby. You have the right to make a complaint at any time to the Data Protection Commission (DPC), the Irish supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the DPC.