Privacy Policy

This Privacy Policy describes how Spinwillow (“we”, “us”, or “our”) collects, uses, and protects information you provide when you access or use the website spinwillow.com (the “Site”) and the free social games offered on it (the “Service”).

Spinwillow is a free-to-play social entertainment service. The Service uses virtual coins only; we do not accept payments, we do not offer real-money prizes, and no aspect of the Service constitutes gambling. By using the Site you agree to the practices described below.

1. Who We Are

Spinwillow operates this Site as a free-to-play social entertainment service. We can be reached at [email protected], by phone on +61 3 9018 7420, or by post at Suite 8, 120 Spencer Street, Melbourne VIC 3000, Australia, for any privacy enquiries, data-subject requests, consent withdrawals, opt-out requests, or complaints.

2. Information We Collect

2.1 Information you provide

• Contact form data — name, email address and message contents when you write to us.
• Account data — if you create an account, your chosen username, email address and any optional profile details.
• Age confirmation — a single record stored locally in your browser indicating you have confirmed you are 18 or older. It does not contain your date of birth.

2.2 Information collected automatically

• Technical data — IP address, browser type and version, operating system, device type, referring URL, pages viewed and timestamps.
• Cookies and similar technologies — see our Cookie Policy.

We do not collect health data, financial-account data, government identifiers, biometric data, or any data classified as sensitive under Article 9 of the EU/UK GDPR.

3. How We Use Your Information

• To operate, maintain and improve the Site and the Service;
• To respond to enquiries, support requests and complaints;
• To verify that visitors meet the minimum age of 18 years;
• To monitor and analyse general usage trends in aggregated, non-identifying form;
• To detect, prevent and investigate abuse, fraud or unauthorised access;
• To comply with applicable laws and lawful requests.

4. Legal Bases (UK / EU GDPR users)

• Consent — for non-essential cookies, analytics and advertising measurement.
• Legitimate interests — for operating, securing and improving the Service.
• Legal obligation — where we are required by law to retain or disclose information.

5. Information Sharing

We do not sell your personal information, and we do not share it for cross-context behavioural advertising except with your consent. We share information only with:

• Service providers who host the Site and deliver content via CDN — including Cloudflare, Inc. — or process analytics, under written agreements limiting their use of the data;
• Law enforcement or public authorities where required by law;
• Advertising partners — including Microsoft Advertising — for measurement and conversion tracking, only after you consent via the cookie banner. If you consent, Microsoft collects and receives personal data to provide Microsoft Advertising; see the Microsoft Privacy Statement. We do not share contact-form contents or account data with advertising partners.

6. International Transfers

Our service providers may process data outside Australia, the UK or the EEA. Where this occurs we rely on appropriate safeguards such as Standard Contractual Clauses, adequacy decisions, or the UK International Data Transfer Agreement.

7. Data Retention

We retain personal data only as long as necessary for the purposes for which it was collected, or as required by law. Contact-form data is retained for up to 24 months. Aggregated analytics data may be retained indefinitely in a non-identifying form.

8. Your Rights

• Access the personal data we hold about you;
• Correct inaccurate or incomplete data;
• Request deletion of your data;
• Object to or restrict certain processing;
• Withdraw consent at any time;
• Opt out of personalised advertising and of use/disclosure of your personal information for direct marketing;
• Receive your data in a portable format;
• Lodge a complaint with your local supervisory authority — in Australia the Office of the Australian Information Commissioner (oaic.gov.au); in the UK the ICO (ico.org.uk).

To exercise any of these rights, email [email protected]. We respond within one month, at no cost, and will not discriminate against you for exercising a right.

9. Your Privacy Choices: Consent, Personalised Ads, and Opt-Out

9.1 Giving consent

Where the law requires consent before we set non-essential cookies or process data for analytics or advertising, we ask through the cookie-consent banner shown on your first visit. Choose “Accept all”, or “Manage” to enable only the categories you agree to. Strictly-necessary cookies (security and age-confirmation) do not require consent.

9.2 Withdrawing consent

• On the Site — use the “Cookie settings” link in the footer, switch off any category and save.
• In your browser — delete stored cookies to clear any recorded consent.
• By email — write to [email protected].

9.3 Opting out of personalised advertising

• Microsoft Advertising — about.ads.microsoft.com/en/resources/policies/personalized-ads.
• Your Online Choices (Australia) — youronlinechoices.com.au.
• Your Online Choices (EU/UK) — youronlinechoices.com.
• Global Privacy Control — we honour the GPC browser signal as a valid opt-out.

9.4 Australian users

The Privacy Act 1988 (Cth) and the Australian Privacy Principles apply. You may access and correct your information and opt out of direct marketing (APP 7). Complaints may go to the OAIC at oaic.gov.au.

10. Children

The Service is strictly for adults aged 18 and older. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us data, contact us and we will delete it without delay.

11. Security

We use industry-standard measures including HTTPS encryption, access controls and regular reviews. No internet transmission is fully secure, but we apply current best practice.

12. Changes

We may update this Policy from time to time; the “Last updated” date reflects the most recent revision.

13. Contact

Questions about this Privacy Policy? Contact [email protected].

Last updated: 19 August 2026