Privacy Policy

Version: 1.0  |  Last Updated: 4 November 2026  |  Domain: therospinau.com

1. Introduction

Welcome to Therospin ("we", "us", "our"). We operate the website available at therospinau.com and are committed to protecting the privacy and personal information of every individual who visits or uses our platform ("you", "user", "player").

This Privacy Policy ("Policy") describes what personal data we collect, the purposes for which we process it, with whom we share it, and the rights available to you regarding your information. It applies to all services, features, and content offered through therospinau.com.

By accessing or using our platform, you acknowledge that you have read and understood this Policy. This document should be read alongside our Terms & Conditions and our Responsible Gaming page, which together form the full framework governing your relationship with Therospin. If you do not agree with this Policy, please discontinue use of our website.

2. Data We Collect

We collect personal data only to the extent necessary to provide our services, comply with legal obligations, and protect the interests of our users. The categories of data we collect include:

2.1 Registration & Identity Data

When you create an account with Therospin, we collect information required to identify you and verify your eligibility to use the platform:

• Full legal name
• Date of birth (to confirm you are aged 18 or older)
• Residential address (including suburb, state, and postcode)
• Email address and phone number
• Username and encrypted password
• Copies of government-issued identity documents (e.g., passport, driver's licence) where required for Know Your Customer (KYC) verification

2.2 Financial & Transaction Data

To facilitate deposits and withdrawals, we collect payment-related information. Accepted payment methods for Australian players include:

• Visa and Mastercard (credit/debit)
• PayPal
• PayID (instant bank transfer)
• Skrill
• Neteller
• Paysafecard
• Neosurf vouchers
• Bitcoin and Ethereum (cryptocurrency)
• Direct bank transfer (BECS / BSB)
• MiFINITY

For each transaction, we record the amount in Australian Dollars (AUD), the payment method used, timestamps, and transaction reference numbers. We do not store full card numbers; tokenised references provided by our payment processors are used instead.

2.3 Technical & Usage Data

Our systems automatically collect information about how you interact with therospinau.com:

• IP address and approximate geolocation
• Browser type and version, operating system, and device identifiers
• Pages visited, session duration, click patterns, and game activity logs
• Referral URL and search terms used to reach our site
• Error logs and performance diagnostics

2.4 Communications Data

When you contact our support team or participate in surveys or promotions, we retain copies of your correspondence, including chat transcripts, emails, and feedback submissions. This helps us resolve disputes, improve service quality, and maintain a record of commitments made.

2.5 Responsible Gaming Data

Where you set deposit limits, cooling-off periods, self-exclusion requests, or other responsible gaming controls as described on our Responsible Gaming page, we record and retain these instructions as a protective measure and to fulfil our obligations under applicable responsible gambling frameworks.

3. How We Use Your Data

We process your personal data for specific, explicit, and legitimate purposes. We do not use your data in ways that are incompatible with those purposes. Our primary uses are:

3.1 Account Management & Service Delivery

We use identity and contact data to create and maintain your account, authenticate your logins, process deposits and withdrawals, and deliver gaming services. This includes verifying that you meet the minimum age requirement of 18 years before granting access to real-money features.

3.2 Compliance & Fraud Prevention

We use identity, financial, and technical data to perform KYC and anti-money laundering (AML) checks, detect and prevent fraudulent activity, enforce self-exclusion decisions, and fulfil reporting obligations imposed by financial intelligence and consumer protection frameworks. Transaction monitoring helps us identify unusual patterns that may indicate misuse of our platform.

3.3 Customer Support

Communications data is used to respond to your enquiries, resolve disputes, and improve our support processes. Support interactions may be monitored for training and quality assurance purposes, subject to appropriate safeguards.

3.4 Personalisation & Marketing

With your consent, we use usage data and game activity to personalise your experience, recommend relevant promotions, and send you marketing communications via email or push notification. You may withdraw consent for direct marketing at any time by clicking "Unsubscribe" in any promotional email or contacting us at [email protected].

3.5 Analytics & Platform Improvement

Aggregated and pseudonymised usage data helps us understand how players navigate the platform, identify technical issues, and develop new features. Where possible, analytics processing uses data that cannot be linked back to a specific individual.

3.6 Responsible Gaming Monitoring

Behavioural data, such as session frequency, deposit velocity, and chasing patterns, is analysed to identify potential signs of problem gambling. This processing is performed in the interest of player welfare. Please refer to our Responsible Gaming page for details of available tools and support resources.

4. Legal Bases for Processing

Every processing activity we carry out rests on at least one recognised legal basis. The following table maps our principal activities to the basis that justifies them:

Where we rely on legitimate interests, we have assessed that our interests do not override your fundamental rights and freedoms. Where we rely on consent, you retain the right to withdraw it at any time without affecting the lawfulness of any processing that occurred before withdrawal.

5. Data Sharing & Third Parties

We do not sell, rent, or trade your personal information. We share data only where it is necessary to operate our services, satisfy legal requirements, or protect the rights and safety of our users. The categories of recipients are:

5.1 Payment Service Providers

When you make a deposit or request a withdrawal, relevant financial data is shared with our authorised payment processors (such as card networks, e-wallet operators, and banking partners) solely for the purpose of completing the transaction. These providers are contractually bound to process your data only on our instructions and to maintain appropriate security standards.

5.2 Identity Verification & AML Partners

We engage regulated third-party KYC and AML service providers to validate identity documents and screen players against sanctions lists and politically exposed person (PEP) databases. Information shared with these partners is limited to what is strictly necessary for verification.

5.3 Technology & Hosting Providers

Our platform relies on cloud infrastructure, game software providers, and customer support tool vendors. These providers access personal data only as data processors acting under our instructions and subject to binding confidentiality agreements.

5.4 Analytics & Marketing Platforms

We may share pseudonymised usage data with analytics partners to measure campaign performance and improve user experience. Where applicable, we ensure that such transfers rely on appropriate data-sharing agreements and that personal data is minimised before transmission.

5.5 Regulatory & Law Enforcement Authorities

We may disclose your personal data to government bodies, regulators, or law enforcement agencies when required to do so by law, court order, or in response to a lawful request. We will notify you of such disclosures where permitted by law.

5.6 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same protections described in this Policy. We will notify you of any material change in data controller before it takes effect.

6. Cookies & Tracking Technologies

Therospin uses cookies and similar technologies (web beacons, pixel tags, local storage) to support the functionality and performance of our website. These technologies help us deliver a seamless experience, analyse traffic, and serve relevant content.

6.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for core site functions such as login session management, security tokens, and load balancing. These cannot be disabled without impairing basic functionality.
• Functional Cookies: Remember your preferences, language settings, and responsible gaming controls between sessions.
• Analytical Cookies: Collect aggregated data about how visitors use the site (pages visited, time spent, errors encountered) to inform platform improvements.
• Marketing Cookies: Track your interactions with our promotional content to measure the effectiveness of advertising campaigns and avoid showing you irrelevant offers.

6.2 Managing Your Cookie Preferences

When you first visit our site, you will be presented with a cookie consent banner. You may accept all categories, or customise your preferences for non-essential cookies. You can update your choices at any time via the Cookie Settings link in the website footer. Please note that disabling certain cookies may limit your ability to use some features of the platform. Most web browsers also offer built-in controls to manage or delete cookies; consult your browser's help documentation for guidance.

7. Data Security

We take the security of your personal data seriously and implement a range of technical and organisational measures designed to protect it against unauthorised access, alteration, disclosure, or destruction.

7.1 Technical Safeguards

• TLS/SSL encryption on all data transmitted between your browser and our servers
• At-rest encryption for sensitive database fields including passwords (bcrypt hashing) and payment tokens
• Regular vulnerability scanning and penetration testing
• Multi-factor authentication (MFA) available to all users and mandatory for administrative access
• Web application firewall (WAF) and DDoS mitigation systems

7.2 Organisational Safeguards

• Role-based access controls limiting staff access to data strictly required for their function
• Mandatory privacy and security training for all personnel handling personal data
• Documented incident response procedures with defined escalation timelines
• Contractual data security obligations imposed on all third-party processors

Despite these measures, no system is entirely immune to risk. If you believe your account has been compromised, please contact us immediately at [email protected]. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify affected individuals and relevant authorities in accordance with applicable law.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

• Account and identity data: Retained for the duration of your account plus a minimum of seven (7) years after account closure, in line with financial record-keeping and AML requirements.
• Transaction records: Retained for a minimum of seven (7) years to satisfy applicable financial and taxation obligations.
• Support communications: Retained for three (3) years after the ticket or case is resolved.
• Marketing preferences and consent records: Retained until you withdraw consent and for a reasonable period thereafter as evidence of compliance.
• Cookie and analytics data: Retained for up to thirteen (13) months, then deleted or fully anonymised.

Upon expiry of the applicable retention period, data is securely deleted or anonymised so that it can no longer be associated with any identifiable individual.

9. Your Rights

As a user of Therospin, you have a number of rights regarding your personal data. We are committed to facilitating the exercise of these rights promptly and without undue obstacle.

9.1 Right of Access

You may request a copy of the personal data we hold about you, together with information about how it is processed, its sources, and the categories of recipients to whom it has been disclosed. We will provide this information in a clear and structured format, free of charge, within 30 days of a verified request.

9.2 Right to Correction

If any personal data we hold is inaccurate, incomplete, or out of date, you have the right to request correction. Many basic details (such as your preferred contact email) can be updated directly within your account settings. For identity data tied to KYC verification, please contact our support team.

9.3 Right to Erasure ("Right to Be Forgotten")

You may ask us to delete your personal data where it is no longer needed for the purpose for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where you object to processing based on legitimate interests and your interests override ours. Please note that we may be required to retain certain data to fulfil legal obligations (see Section 8), in which case we will inform you of any data we cannot delete and the reason why.

9.4 Right to Restriction of Processing

You may request that we limit how we use your data in certain circumstances — for example, while a correction request is being assessed, or where you have objected to processing based on legitimate interests and we are evaluating whether our interests override yours.

9.5 Right to Data Portability

Where processing is based on your consent or on the performance of a contract, and carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format (such as CSV or JSON), and to transmit that data to another service provider where technically feasible.

9.6 Right to Object

You have the right to object at any time to processing that relies on our legitimate interests, including profiling for direct marketing purposes. If you object to direct marketing, we will cease processing your data for that purpose immediately and without question.

9.7 Withdrawing Consent

Where we process your data on the basis of consent, you may withdraw that consent at any time by contacting us at [email protected] or by using the opt-out mechanisms within the platform. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

9.8 Exercising Your Rights

To submit a data rights request, email us at [email protected] with the subject line "Data Rights Request" and include sufficient information to allow us to verify your identity. We will acknowledge your request within 5 business days and respond substantively within 30 days. Where we require additional time due to complexity or volume of requests, we will notify you of the extension and the reasons for it. We will never charge a fee for a first request of each type within a 12-month period; we reserve the right to charge a reasonable fee for manifestly excessive or repetitive requests.

9.9 Responsible Gaming & Self-Exclusion Rights

Self-exclusion requests and responsible gaming controls are treated as binding instructions. Attempting to circumvent a self-exclusion by creating a new account or by misrepresenting your identity is a breach of our Terms & Conditions. During any active self-exclusion period, we will suppress all direct marketing communications addressed to the excluded account.

10. International Data Transfers

Our operations and those of our third-party service providers may involve the transfer or storage of personal data outside Australia. When such transfers occur, we ensure that appropriate safeguards are in place to protect your information to a standard that is at least equivalent to that afforded under Australian privacy principles.

Safeguards we rely on include:

• Contractual clauses imposing data protection obligations on overseas recipients
• Transferring data only to jurisdictions recognised as having comparable privacy protections
• Binding corporate rules or equivalent internal standards where data is shared within a group of companies
• Your explicit consent, where required and where you are informed of the destination country and associated risks

Prior to transferring your data internationally, we conduct reasonable due diligence to ensure that overseas recipients are capable of and committed to handling your data responsibly and securely. If you would like more information about the specific safeguards applicable to a particular transfer, please contact us at [email protected].

11. Minors

Therospin is strictly an adults-only platform. Our services are not directed at, and must not be accessed by, any person under the age of 18 years. We do not knowingly collect or process personal data belonging to individuals under 18.

During registration, all users are required to confirm that they are aged 18 or older and to submit to identity verification. If we discover or have reason to believe that a minor has created an account, we will immediately suspend access, delete the account and all associated personal data, and reverse any transactions to the extent possible.

If you believe a minor has accessed our platform, please notify us immediately at [email protected]. Parents and guardians are encouraged to use parental control software to restrict access to online gambling platforms. For further safeguarding information, please visit our Responsible Gaming page.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other legitimate business reasons. When we make material changes, we will update the Last Updated date at the top of this document and, where appropriate, notify you by email or by displaying a prominent notice on our website prior to the change taking effect.

We encourage you to review this Policy periodically. Your continued use of therospinau.com following the posting of any revised version constitutes your acceptance of the updated terms. If you disagree with any changes, you should cease using the platform and may request account closure by contacting [email protected]. Previous versions of this Policy are available upon request.

13. Contact Information

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact us using the details below:

We will acknowledge all privacy-related enquiries within 5 business days and provide a full response within 30 days, unless the matter requires further investigation, in which case we will keep you informed of progress.

Responsible Gambling Support in Australia

Therospin is committed to player welfare. If you or someone you know is experiencing difficulties related to gambling, the following free, confidential support services are available to Australians:

• Gambling Help Online — Free, 24/7 telephone and online counselling: 1800 858 858 | gamblinghelponline.org.au
• Lifeline Australia — Crisis support for stress, anxiety, and mental health issues linked to gambling: 13 11 14 (available 24/7) | lifeline.org.au
• Gambler's Help — Counselling, financial support, and group programs across Victoria and other states: 1800 858 858 | gamblerhelp.org.au
• MensLine Australia — Support for men experiencing gambling-related distress: 1300 789 978 (available 24/7) | mensline.org.au
• BetStop — National Self-Exclusion Register — Register to block yourself from all licensed Australian online gambling services, free of charge | betstop.gov.au
• National Debt Helpline — Free financial counselling for those experiencing debt related to gambling: 1800 007 007 | ndh.org.au

For more information on responsible gambling tools available through Therospin, please visit our Responsible Gaming page.