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Privacy Policy

Last updated : May 28, 2026

This document is a template to be reviewed by legal counsel before going to production.

1. Data controller

The data controller is [COMPANY NAME], located at [FULL ADDRESS], Switzerland. Contact: [DPO / CONTACT EMAIL].

2. Data we collect

We process the following categories of data:

  • Account data: email, agency identifiers, role.
  • Usage data: wheels created, spins, statistics.
  • Payment data: amounts, methods, transaction identifiers (card data does not pass through SpinLink).
  • Telegram identifiers: user ID, pseudonymized where applicable.

3. Purposes

Data is processed to provide the service, manage billing and payouts, ensure security and improve the product. [To complete: legal bases under GDPR / Swiss FADP.]

[To be completed by legal counsel: contract performance, legitimate interest, consent, legal obligation.]

5. Data sharing

Data may be shared with our processors (hosting, payments, analytics) strictly as necessary. [To complete: list of processors and transfers outside the EU/Switzerland.]

6. Retention

[To complete: retention periods per data category.]

7. Your rights

Under the GDPR and the Swiss FADP, you have the right to access, rectify, erase, port and object to the processing of your data. To exercise them: [DPO / CONTACT EMAIL].

8. Cookies

[To complete: essential cookies, analytics, consent management.]

9. Security

We implement appropriate technical and organizational measures to protect your data.

10. Changes

This policy may be updated. The date of the last update appears at the top of the document.