Privacy policy

The data controller is Matthew [SURNAME — TO CONFIRM], an individual trading as MattySpins, at [CONTACT ADDRESS — TO CONFIRM]. Data questions go to [CONTACT EMAIL — TO CONFIRM].

[WHETHER A UK/EU REPRESENTATIVE OR ICO REGISTRATION IS REQUIRED — TO CONFIRM]

• Your Discord account id, username and avatar. This is your identity on the site. We ask Discord for the identify and guilds scopes so we can confirm you are a member of the server. We never see your Discord password or email.
• Your Kick user id and username, once you verify by typing a short code in chat. We key off the numeric id, because usernames change.
• Your coin ledger. Every coin earned, spent, won, lost or adjusted, with the reason. This is an accounting record and it is append-only.
• Game rounds you play — the bet, the outcome, the payout, and the seed values that let anyone verify the round.
• A Razed username, if you claim a prize. You give it to us; we check it against the frozen leaderboard snapshot. We do not have access to your Razed account.
• A hash of your IP address, used to spot networks of duplicate accounts. We store the hash, not the address, and we never ban on it alone.

We do not store payment details, because there is nothing on this site to pay for. We do not ask for your real name or address unless you redeem something that has to be posted to you.

For your account, your coins and your redemptions, we process your data to perform the agreement you entered into by signing up.

For fraud and multi-account detection, and for keeping prize records, we rely on our legitimate interest in running a fair site and being able to show that prizes went where we said they did.

[LAWFUL BASES TO BE CONFIRMED BY COUNSEL]

The site runs on hosting, database and error-monitoring services acting on our instructions. They process data to keep the site running and for nothing else.

Masked usernames are public. Leaderboard positions, giveaway winners and big wins appear on the site in masked form. Prize records are kept permanently, because a giveaway nobody can audit is not a giveaway.

We do not sell your data, and we do not share it with Razed. Razed sends us wagering figures for accounts under our referral code; nothing goes the other way.

[FULL PROCESSOR LIST AND ANY INTERNATIONAL TRANSFERS — TO CONFIRM]

We use a session cookie to keep you signed in, and browser storage to remember that you confirmed your age. Both are necessary for the site to work and neither tracks you across other websites.

[ANALYTICS — IF PLAUSIBLE/UMAMI IS ADDED, DESCRIBE IT HERE]

Your account and its data are kept while the account is open. A balance is forfeited after 90 days of inactivity, though the account remains.

Ledger rows and prize records outlive the account in anonymised form. They are the record of every coin issued and every prize paid, and removing them would make the site unauditable.

There is a delete button on your profile page. It removes your Discord link, your Kick link and your balance immediately and permanently.

What survives: ledger rows with your identity stripped out; any giveaway you won, because the winner list is never edited; and any prize claim already paid, because that is a financial record.

You can ask for a copy of what we hold, ask us to correct it, ask us to delete it, object to how we are using it, or ask us to restrict it. Write to [CONTACT EMAIL — TO CONFIRM] and we will respond within one month.

If you are not satisfied you can complain to your data protection regulator — in the UK, the Information Commissioner’s Office at ico.org.uk. This policy is governed by the law of England and Wales [TO CONFIRM WITH COUNSEL].

The site is not for anyone under 18 and we do not knowingly hold data about anyone under 18. If you believe we do, tell us and we will delete it.