Privacy Policy
How we handle your data at Spin Formula

Introduction

Spin Formula ("we", "us" or "our") operates fodawbay.co.uk (the "site"). We are the data controller for personal data collected on this site. If you play on the underlying gambling platform we link to from this site, that operator is a separate data controller for the account, deposit, wager and payout data held on its systems, and its own privacy policy applies inside your account.

This policy describes only the data we collect on fodawbay.co.uk. It complements the operator's account privacy notice rather than replacing it. If any part of this policy is unclear, contact us at [email protected] before you continue to use the site.

Personal data we collect on this site

On fodawbay.co.uk we collect a small set of technical and traffic data on every visit:

• Device and browser data - user-agent, screen size, operating system, browser version, referring page and language preference.
• Connection data - IP address, approximate location (country and region only), timestamps and connection type.
• Behavioural data - pages viewed, buttons and links clicked, scroll depth and session duration.
• Cookies and similar identifiers - see the Cookies section below.

We do not run a signup form or a deposit form on fodawbay.co.uk. We do not collect your name, email address, phone number, home address, date of birth, payment details or gambling history on this site. Any account, deposit and gambling data is collected by the operator platform after you follow the sign-in or signup link, under the operator's own privacy notice.

How we use your data and our lawful basis

We use the technical and traffic data described above for the following purposes:

• Site operation and security - to render pages, prevent abuse, defend against fraud and denial-of-service attacks, and keep the site available.
• Site analytics - to understand which pages are useful, where the site can be improved and how visitors move between the home, bonuses and login pages.
• Marketing measurement - to measure how many visitors reach us from each marketing channel and whether they went on to open an account on the operator platform.
• Legal and regulatory compliance - to keep the records we need in order to answer complaints, subject access requests and requests from regulators.

Our lawful basis under UK GDPR is legitimate interests for site operation, security and marketing measurement, and consent for non-essential cookies and analytics. Consent is collected through the cookie banner and can be withdrawn at any time by clearing your cookies and revisiting the site.

Cookies and similar technologies

fodawbay.co.uk uses a small number of first-party cookies. We do not sell your cookie data. The categories are:

• Strictly necessary - session identifiers and CSRF tokens that keep the site working. These cookies are set on every visit and cannot be switched off.
• Preferences - your language, theme and consent preferences. Set only if you interact with the cookie banner or a preference control.
• Analytics - aggregate visit measurement (page views, referrers, click events). Set only if you accept analytics on the cookie banner.
• Marketing measurement - a click identifier that lets us tie your visit back to the marketing channel that referred you. Set only if you accept marketing measurement on the cookie banner.

You can clear or block cookies at any time in your browser settings. Blocking strictly necessary cookies will stop the site from working; blocking the other categories does not affect the site experience.

Who we share data with

We share the limited data described above with a small number of processors that act only on our instructions and under written contracts that meet UK GDPR requirements:

• Hosting and content delivery - the servers and CDN that host and deliver fodawbay.co.uk.
• Analytics and marketing measurement - the aggregated analytics platform that summarises site traffic and channel performance.
• Security and abuse prevention - the firewall and bot-management service that protects the site.
• Regulators and law enforcement - only where we are legally required to share information under UK law.

We do not share your data with advertisers or data brokers, and we do not sell your data. If you follow a link off this site to the operator platform, any data you enter there is governed by the operator's own privacy notice, not this one.

International transfers

Our hosting, analytics and security processors may store or process data outside the United Kingdom or the European Economic Area. Where this happens, we rely on the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses to keep the level of protection at least equivalent to UK GDPR. A summary of these safeguards is available on request.

How long we keep your data

The technical, traffic and analytics data we collect on this site is kept for a maximum of 26 months after your visit and then either deleted or fully anonymised. Cookie preferences are kept for the lifetime of the cookie you agree to (usually 12 months). Records that we have to keep to answer a complaint, a subject access request or a regulatory query are kept for as long as the law requires and no longer.

Your rights under UK GDPR

You have the following rights over the data we hold about you on this site:

• Right of access - a copy of the personal data we hold about you.
• Right to rectification - to have inaccurate data corrected.
• Right to erasure - to have your data deleted where the law allows.
• Right to restrict processing - to limit how we use your data.
• Right to data portability - to receive your data in a portable format.
• Right to object - to object to processing based on legitimate interests or direct marketing.
• Right to withdraw consent - where our lawful basis is consent, you can withdraw it at any time.
• Right to complain - to the Information Commissioner's Office at ico.org.uk.

To exercise any of these rights, email [email protected]. We reply within one calendar month; the deadline can be extended by up to two further months for complex requests and we will tell you if that happens.

Children's data

Spin Formula is a gambling brand and this site is for adults aged 18 and over. We do not knowingly collect data from under-18s. If you believe an under-18 has interacted with this site, contact us at [email protected] and we will delete any relevant records.

Changes to this policy

We may update this policy from time to time. Material changes are announced on this page and the "last updated" date at the top of the introduction is refreshed. Continued use of the site after a change means you accept the updated policy.

How to contact us about privacy

Send privacy queries to [email protected]. General account questions are handled by the operator support team through the in-account contact form on the gambling platform.