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CCPA Compliance

This notice tells California residents what personal information SpinVisor collects and how to use CCPA/CPRA rights such as access, deletion, and correction.

Effective Date: 21st Sep 2026
Last Updated: 23rd Sep 2026

1. Purpose of This Notice

This California Privacy Notice supplements the SpinVisor Privacy Policy and applies to residents of California where the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), applies.

SpinVisor is operated by Dynemetry (Pty) Ltd, South Africa.

This Notice explains:

  • categories of personal information SpinVisor may collect;
  • sources of that information;
  • purposes for which the information is used;
  • categories of recipients;
  • SpinVisor's commercial use of gameplay telemetry;
  • California privacy rights; and
  • how California residents may exercise applicable rights.

The SpinVisor Privacy Policy remains the primary description of SpinVisor's overall privacy practices.

2. Application of the CCPA

The CCPA applies to qualifying for-profit businesses doing business in California that meet applicable statutory thresholds.

SpinVisor's status under those thresholds may change as its business develops.

Where SpinVisor is legally subject to the CCPA, SpinVisor will provide and honour the rights required by the CCPA.

SpinVisor may also choose to provide some privacy controls voluntarily even where a particular statutory requirement does not apply.

Nothing in this Notice is intended to represent that a statutory requirement applies where it does not.

3. California Personal Information

Under the CCPA, personal information generally includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Depending on the circumstances, information processed by SpinVisor may therefore constitute personal information even where it does not contain a person's real name.

SpinVisor distinguishes between:

  • personal information;
  • pseudonymous/account-linked information;
  • gameplay telemetry;
  • aggregate information; and
  • deidentified information.

4. Categories of Personal Information

Depending on how a California resident interacts with SpinVisor, SpinVisor may collect or process categories of personal information including the following.

Identifiers

Examples may include:

  • email address;
  • IP address;
  • internal SpinVisor account identifier;
  • SpinVisor handle;
  • installation identifier; and
  • authentication/session identifiers.

Customer/account information

Examples may include:

  • account status;
  • subscription tier;
  • subscription information;
  • account creation information; and
  • account preferences.

Characteristics

SpinVisor requires date of birth for age-eligibility screening.

Users may also voluntarily provide their country of residence.

Commercial information

Where applicable, this may include:

  • subscription tier;
  • subscription status;
  • billing cycle;
  • subscription start/end information;
  • transaction/order references;
  • payment status; and
  • payment-provider customer/subscription identifiers.

SpinVisor does not intend to receive or store complete payment-card numbers, CVVs or online-banking credentials.

Internet or electronic activity

Examples may include:

  • browser information;
  • operating-system information;
  • extension version;
  • supported website/domain;
  • API activity;
  • application logs;
  • diagnostic information;
  • security events; and
  • interaction with SpinVisor services.

Gameplay and session information

While linked or reasonably linkable to a SpinVisor account, this may include:

  • game;
  • game provider;
  • casino/website;
  • gameplay events;
  • wager values;
  • spin results;
  • win/loss values;
  • displayed gameplay balances;
  • bonus/feature information;
  • multiplier information;
  • session records;
  • observed RTP;
  • session profit/loss;
  • historical gameplay statistics; and
  • other gameplay-derived metrics.

Approximate location

SpinVisor may derive an approximate country or region from an IP address.

SpinVisor does not request precise GPS location as part of its described service.

User-provided profile information

Where voluntarily provided:

  • first name;
  • last name;
  • country of residence; and
  • profile photograph.

Inferences and derived analytics

SpinVisor may calculate information from gameplay activity, including:

  • observed RTP;
  • win rate;
  • average wager;
  • average win;
  • net result per spin;
  • feature statistics;
  • tumble/cascade statistics;
  • variance-related metrics;
  • session-performance statistics; and
  • other historical or mathematical gameplay measurements.

5. Sources of Personal Information

SpinVisor may obtain personal information from:

Directly from the user

For example:

  • email address;
  • date of birth;
  • optional profile information;
  • account preferences;
  • support information; and
  • newsletter subscription choices.

Automatically through SpinVisor

For example:

  • IP addresses;
  • authentication/session information;
  • application logs;
  • extension information;
  • API activity; and
  • security information.

Supported gameplay environments

Where the user has granted the required browser access, SpinVisor may observe supported gameplay telemetry from supported casino/game environments.

Derived by SpinVisor

SpinVisor generates analytics and statistical information from gameplay telemetry and session history.

Service providers

Limited information may be received from payment, infrastructure or other operational service providers where necessary to operate SpinVisor.

6. Business and Commercial Purposes

SpinVisor may collect, use or process personal information for purposes including:

  • providing accounts;
  • authenticating users;
  • age-eligibility screening;
  • providing the browser extension;
  • processing supported gameplay telemetry;
  • creating gameplay/session history;
  • calculating gameplay statistics;
  • providing community functionality;
  • managing subscriptions;
  • processing payments through external providers;
  • providing support;
  • providing essential communications;
  • maintaining security;
  • preventing fraud and abuse;
  • troubleshooting;
  • maintaining service reliability;
  • improving SpinVisor;
  • complying with legal obligations; and
  • establishing, exercising or defending legal rights.

SpinVisor also commercially uses gameplay telemetry datasets as described in Section 10.

7. Sensitive Personal Information

The CCPA defines certain categories of information as sensitive personal information.

SpinVisor is not designed to collect categories such as:

  • Social Security numbers;
  • government identity-document numbers;
  • complete financial-account credentials;
  • complete payment-card credentials together with required security credentials;
  • precise geolocation;
  • private email/message contents unrelated to SpinVisor;
  • genetic data;
  • biometric identifiers used for identification; or
  • information concerning health, sex life, sexual orientation, racial or ethnic origin, religious/philosophical beliefs or union membership.

SpinVisor does process authentication information required to secure SpinVisor accounts.

SpinVisor does not use sensitive personal information for purposes intended to infer characteristics about users beyond purposes necessary to provide, secure or administer the Service.

Where the CCPA grants a right to limit the use or disclosure of sensitive personal information and SpinVisor engages in processing subject to that right, SpinVisor will provide the required mechanism.

8. Gameplay Information

SpinVisor processes gameplay telemetry to provide tracking, metrics, session history and analytics.

While gameplay information remains linked or reasonably linkable to a SpinVisor account or household, it may constitute personal information under the CCPA.

SpinVisor therefore does not assume that gameplay information becomes non-personal merely because the user's real name is absent.

9. Pseudonymous Handles

SpinVisor automatically assigns a pseudonymous handle to an account.

Handles may be used in community functionality.

SpinVisor does not treat an account-linked handle as necessarily deidentified information merely because the handle does not contain the user's real name.

Commercial telemetry datasets described below do not contain SpinVisor handles.

10. Commercial Gameplay Telemetry

SpinVisor's business model may include the commercial use, licensing or sale of gameplay telemetry event data and statistical datasets to third-party casino-industry and gameplay-data aggregators.

Such datasets may contain information concerning:

  • game titles;
  • game providers;
  • casino/website context;
  • gameplay events;
  • wager values;
  • spin activity and outcomes;
  • win/loss values;
  • bonus/feature events;
  • multiplier events;
  • game-related telemetry; and
  • statistical information derived from gameplay telemetry.

Commercial telemetry datasets supplied to these recipients do not include user/account references such as:

  • SpinVisor handles;
  • anonymised or pseudonymised handles;
  • SpinVisor account IDs;
  • email addresses;
  • dates of birth;
  • IP addresses;
  • first or last names;
  • profile photographs;
  • authentication information; or
  • other identifiers intended to associate telemetry events with a particular SpinVisor user.

SpinVisor may receive financial or other commercial consideration for supplying gameplay telemetry datasets.

11. CCPA “Sale” and “Sharing”

The CCPA uses specific statutory definitions of “sale” and “sharing” of personal information.

Accordingly, the fact that SpinVisor commercially licenses or sells a telemetry dataset does not, by itself, determine whether the transaction constitutes a “sale” of personal information under the CCPA.

SpinVisor's intended commercial telemetry model excludes user/account references from the datasets supplied to recipients.

SpinVisor will assess commercial telemetry arrangements according to the CCPA's applicable definitions and requirements, including whether information is personal information, aggregate consumer information or deidentified information.

SpinVisor will not describe information as outside the CCPA merely because obvious identifiers have been removed if the information can still reasonably be linked to a consumer or household.

Where a commercial disclosure constitutes a CCPA sale or sharing of personal information, SpinVisor will provide the disclosures, opt-out mechanisms and other protections required by applicable law.

12. Deidentified Information

Where SpinVisor maintains information as deidentified information for purposes of the CCPA, SpinVisor intends to maintain that information in deidentified form and not attempt to reidentify the information except where legally permitted for purposes such as determining whether deidentification processes satisfy applicable requirements.

SpinVisor applies technical and organisational measures intended to prevent deidentified information from being associated with a particular consumer.

Where deidentified information is disclosed to another party, SpinVisor will apply contractual or other safeguards required by applicable law.

13. Aggregate Information

SpinVisor may generate aggregate statistical information concerning gameplay, games, providers, features and other activity.

Where information qualifies as aggregate consumer information or otherwise falls outside the definition of personal information under the CCPA, SpinVisor may use that information for:

  • statistical analysis;
  • industry analytics;
  • service improvement;
  • product development;
  • research;
  • market intelligence; and
  • commercial licensing.

14. Categories of Third Parties

Depending on the processing activity, SpinVisor may disclose information to categories of third parties including:

  • hosting providers;
  • cloud infrastructure providers;
  • CDN/security providers;
  • transactional email providers;
  • payment processors;
  • Merchant of Record/payment providers;
  • tax-management providers;
  • professional advisers;
  • governmental or regulatory authorities where legally required; and
  • gameplay-data or casino-industry aggregators receiving commercial telemetry datasets as described in this Notice.

Current infrastructure providers may include:

  • Vander Host;
  • Amazon Web Services (AWS); and
  • Cloudflare.

The applicable payment and tax providers will be identified when those arrangements are finalised where disclosure is required.

15. Right to Know

Where the CCPA applies, California residents may have the right to request information concerning SpinVisor's collection and processing of their personal information.

A qualifying request may include information concerning:

  • categories of personal information collected;
  • categories of sources;
  • business or commercial purposes;
  • categories of third parties to whom information is disclosed;
  • categories of personal information sold or shared, where applicable; and
  • specific pieces of personal information collected about the consumer.

Requests remain subject to applicable CCPA requirements and exceptions.

16. Right to Delete

Where applicable, California residents may request deletion of personal information SpinVisor has collected from them.

The right to deletion is subject to exceptions permitted by law.

SpinVisor also provides account-deletion functionality.

Following account deletion:

  • account access terminates;
  • account-linked personal information is removed from active production systems according to SpinVisor's deletion process;
  • the user loses access to their historical gameplay records; and
  • retained historical gameplay information is anonymised.

Properly anonymised historical gameplay information cannot subsequently be restored to the former account.

17. Right to Correct

California residents may have the right to request correction of inaccurate personal information maintained by SpinVisor.

Certain profile/account information may also be editable directly through SpinVisor.

SpinVisor may take reasonable steps to determine the accuracy of information subject to a correction request.

18. Right to Opt Out of Sale or Sharing

Where SpinVisor sells or shares personal information within the meaning of the CCPA, California residents have the right to direct SpinVisor not to sell or share their personal information.

SpinVisor will provide the legally required opt-out mechanism where this right applies.

SpinVisor will also honour legally valid opt-out preference signals, including Global Privacy Control, where required by the CCPA.

An opt-out from the sale or sharing of personal information does not necessarily apply to information that has been validly deidentified or aggregated and is outside the applicable statutory definition of personal information.

SpinVisor will not use deidentification as a means of circumventing a valid privacy right where the information remains reasonably linkable to a consumer or household.

19. Global Privacy Control

Where required by the CCPA, SpinVisor will recognise a valid Global Privacy Control (“GPC”) signal as an opt-out request concerning the sale or sharing of personal information for the browser/device from which the signal is received, subject to applicable regulatory requirements.

Where SpinVisor can associate the signal with an authenticated California user's account and applicable law requires broader application, SpinVisor will process the request accordingly.

SpinVisor will not require a user to disable GPC in order to access ordinary SpinVisor functionality where doing so would conflict with applicable law.

20. Right to Limit Use of Sensitive Personal Information

Where SpinVisor processes sensitive personal information for purposes that trigger the CCPA's right to limit, California residents may exercise the applicable right to limit its use or disclosure.

SpinVisor does not intend to use sensitive personal information for unrelated advertising profiling or to infer sensitive characteristics about users.

If SpinVisor's processing changes in a manner that triggers additional obligations, this Notice and the applicable privacy controls will be updated.

21. Right to Non-Discrimination

SpinVisor will not unlawfully discriminate against a California resident for exercising a right granted by the CCPA.

Subject to applicable law, SpinVisor will not because of a valid privacy request:

  • deny ordinary services;
  • charge a different price;
  • provide a materially different level or quality of service; or
  • retaliate against the consumer

where such conduct would violate the CCPA.

Certain functionality may necessarily become unavailable where information required to provide that functionality has been deleted at the consumer's request.

22. Requests Through an Authorised Agent

California residents may use an authorised agent to submit certain CCPA requests where permitted by law.

SpinVisor may request evidence that the agent is authorised to act on the consumer's behalf.

SpinVisor may also request direct verification from the consumer where permitted.

Verification information will be used for the purpose of processing and protecting the privacy request.

23. Verification of Requests

SpinVisor may need to verify a consumer's identity before responding to requests involving access, deletion or correction of personal information.

Verification measures will be proportionate to:

  • the type of request;
  • the sensitivity of the information;
  • the risk of unauthorised disclosure or deletion; and
  • the information already available to SpinVisor.

SpinVisor will not intentionally disclose account information to an unauthorised requester.

24. How to Exercise California Privacy Rights

California privacy requests may be submitted using the methods made available by SpinVisor.

These may include:

Privacy Email: support@spinvisor.com

Where legally required, SpinVisor will provide additional request methods.

A request should provide sufficient information to enable SpinVisor to understand and process the request without unnecessarily collecting additional personal information.

25. Response to Requests

SpinVisor will respond to valid California privacy requests within the periods required by applicable law.

Where additional time is permitted and reasonably necessary, SpinVisor will notify the requester according to applicable requirements.

SpinVisor will ordinarily provide required responses without charge.

Where the CCPA permits a request to be denied or a fee to be charged because a request is manifestly unfounded, excessive or otherwise falls within a statutory exception, SpinVisor may apply the relevant provision.

26. Requests to Opt Out

Where a CCPA opt-out right applies, SpinVisor will process valid opt-out requests within the period required by applicable law.

SpinVisor will not require a consumer to create a new SpinVisor account merely to exercise an applicable opt-out right.

Where necessary, SpinVisor may request limited information to identify the data or processing to which the opt-out applies.

27. Retention

SpinVisor retains personal information according to the purpose for which it is processed.

As described more fully in the Privacy Policy:

  • account information is generally retained while the account remains active, subject to the 60-day inactivity process;
  • account-linked gameplay/session information is retained during the life of the account;
  • technical/security logs are generally retained for approximately 90 days to 12 months;
  • registration IP information may generally be retained for approximately 90 days to 12 months for security purposes;
  • failed under-age registration attempts may generally be retained for approximately 90 days to 12 months;
  • closed support tickets are generally retained for approximately 30 days after closure;
  • newsletter information is retained until unsubscribe, with minimum suppression information retained as necessary to honour the opt-out;
  • subscription, accounting and tax information is retained for applicable statutory periods; and
  • genuinely anonymised historical gameplay/statistical information may be retained indefinitely.

SpinVisor seeks not to retain identifiable personal information longer than reasonably necessary for its disclosed purposes.

28. Account Inactivity

If no qualifying account activity is detected for 30 consecutive days, SpinVisor may notify the user that the account is inactive and scheduled for deletion on Day 60.

A further reminder may be sent at approximately Day 45.

Qualifying use of the SpinVisor extension or SaaS backend before Day 60 resets the inactivity process.

If inactivity continues through Day 60, SpinVisor may:

  • delete the account;
  • remove account-linked personal information from active production systems;
  • anonymise retained historical gameplay information; and
  • notify the former user.

Previously anonymised gameplay information cannot be restored to a subsequently created account.

29. Backups

Information deleted from active production systems may temporarily remain in restricted backup systems.

SpinVisor generally operates a rolling backup lifecycle as described in the Privacy Policy.

Residual backups containing deleted personal information are expected to expire or be overwritten through the normal backup lifecycle within approximately 60 days following deletion from active production systems.

Backups are not intended to restore an individual user's account following deliberate account deletion.

30. Children

SpinVisor is restricted to persons 18 years of age or older.

SpinVisor therefore does not intentionally provide the Service to children under 16 and does not intentionally sell or share the personal information of children under 16.

Date of birth is required during registration for age-eligibility screening.

Where the supplied date of birth indicates that the individual is under 18, registration/access is denied.

SpinVisor does not currently perform independent government-identity verification to determine whether a person has supplied a false date of birth.

31. Browser Extension Data

The SpinVisor browser extension processes information required to provide gameplay tracking and analytics on supported websites where appropriate browser access has been granted.

Users control browser-level website permissions where the browser provides such controls.

Detailed information concerning extension data processing is provided in the SpinVisor Extension Data Collection Statement.

32. Unsupported Websites

Where SpinVisor is opened on an unsupported website, the extension may inform the user that SpinVisor does not currently operate on that website.

SpinVisor may provide access to information concerning currently supported casino websites.

SpinVisor does not represent an unsupported website as supported.

33. Security

SpinVisor uses technical and organisational measures intended to protect personal information.

Measures may include:

  • password hashing;
  • authenticated access;
  • access controls;
  • security logging;
  • infrastructure controls;
  • restricted administrative access;
  • backups;
  • security monitoring; and
  • incident-response processes.

No Internet-based service can guarantee absolute security.

34. California “Shine the Light”

California Civil Code section 1798.83 may provide certain California residents with rights concerning disclosure of personal information to third parties for those third parties' direct-marketing purposes.

SpinVisor does not intend to disclose users' personal information to unrelated third parties for those third parties to independently market products or services directly to the user.

Questions concerning applicable California disclosure rights may be submitted through SpinVisor's privacy contact.

35. Changes to This Notice

SpinVisor may update this California Privacy Notice to reflect:

  • changes to processing;
  • changes to commercial telemetry arrangements;
  • changes to infrastructure;
  • changes to California privacy law;
  • regulatory guidance;
  • new SpinVisor functionality; or
  • other material developments.

The “Last Updated” date will be revised when this Notice changes.

Material changes will be communicated where required by applicable law.

36. Relationship With Other SpinVisor Policies

This Notice should be read together with:

  • SpinVisor Privacy Policy;
  • SpinVisor Terms of Service;
  • SpinVisor Extension Data Collection Statement;
  • SpinVisor GDPR Compliance & Rights Notice;
  • SpinVisor POPIA Compliance Notice;
  • Cookie Policy;
  • Responsible Gambling / Responsible Play Policy;
  • Subscription, Cancellation & Refund Policy; and
  • Gambling & Analytics Disclaimer.

37. Contact

California privacy enquiries may be directed to:

SpinVisor
A division of Dynemetry (Pty) Ltd
South Africa

Website: www.spinvisor.com
Privacy Email: support@spinvisor.com
Business/Registered Address: 10 Payne St, Penzance Estate, Cape Town, Western Cape, 7806

California residents may use these channels to request information or exercise applicable privacy rights.

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