Privacy Policy

Last updated: 2026. This privacy policy explains how Ludaro Limited ("SpinSkull", "we", "us") collects and processes your personal data when you use spin-skull.com.se. It is written to comply with the EU General Data Protection Regulation (GDPR) and applicable Maltese data protection legislation.

1. Data we collect

We collect: account data (name, date of birth, address, email, phone number); KYC data (government-issued ID, proof of address, source of funds where required); transaction data (deposits, withdrawals, gaming history, bonus activations); technical data (IP address, device, browser, session data, cookies); and marketing preferences and communications with support.

2. How we use your data

• To operate your account, process transactions, and provide gaming services.
• To fulfil our legal and regulatory obligations (KYC, AML, responsible gaming).
• To improve the service, detect fraud, and prevent abuse.
• To send relevant offers and updates where you have opted in (with opt-out available at any time).

3. Cookies

We use strictly necessary cookies for session management and security, as well as preference and analytics cookies to improve the experience. Marketing cookies are set only with your consent. You can manage cookie settings via the cookie banner shown on your first visit or via your browser settings.

4. KYC and AML data

As a licensed operator we are required to verify the identity of all players who deposit or withdraw. KYC documents are stored encrypted and processed only by our compliance team. We retain KYC and transaction data for a minimum of five years after account closure, in accordance with EU AML rules.

5. Marketing and opt-out

You may opt out of marketing communications at any time via the player area or the "Unsubscribe" link in any marketing email. Transactional messages (deposit confirmations, withdrawal status, KYC requests) cannot be disabled as they are necessary for the service.

6. Data retention

We retain your personal data for as long as your account is active and thereafter for as long as required by law (typically five years for transaction and KYC data). Data outside legal retention requirements is deleted or anonymised upon account closure.

7. Your rights under GDPR

• Right of access — request a copy of the data we hold about you.
• Right of rectification — correct inaccurate or incomplete data.
• Right to erasure — request deletion after legal retention requirements have lapsed.
• Right to data portability — receive your data in a machine-readable format.
• Right to object — object to processing based on legitimate interests.
• Right to lodge a complaint — submit a complaint to the Information and Data Protection Commissioner (IDPC) in Malta.

8. Data transfers

Your data is stored within the EU/EEA. Where we use providers outside the EU/EEA (for example third-party support or analytics), we do so under standard contractual clauses or equivalent safeguards approved by the European Commission.

9. Contact the DPO

For questions about this policy or to exercise your rights, contact our Data Protection Officer at [email protected]. For general support: [email protected].