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POPIA Compliance

This notice explains how Dynemetry (Pty) Ltd processes personal information under South Africa's Protection of Personal Information Act.

Effective Date: 21st Sep 2026
Last Updated: 28th Sep 2026

1. Purpose of This Notice

This POPIA Compliance Notice explains how SpinVisor addresses the requirements of the Protection of Personal Information Act 4 of 2013 (“POPIA”) of the Republic of South Africa.

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

This Notice supplements the SpinVisor Privacy Policy and should be read together with that policy.

The Privacy Policy provides the primary description of:

  • personal information collected by SpinVisor;
  • purposes for which information is processed;
  • gameplay telemetry;
  • account information;
  • retention;
  • anonymisation;
  • security;
  • infrastructure; and
  • privacy rights.

This Notice focuses specifically on POPIA.

2. Responsible Party

For personal information processed for SpinVisor's own purposes, the responsible party is:

Dynemetry (Pty) Ltd
SpinVisor division
South Africa

Registration Number: 2026/492353/07
Registered/Business Address: 10 Payne St, Penzance Estate, Cape Town, Western Cape, 7806
Privacy Email: support@spinvisor.com

Under POPIA terminology, the “responsible party” is the party that determines the purpose of and means for processing personal information.

3. Information Officer

Dynemetry (Pty) Ltd is required to maintain the Information Officer arrangements applicable to it under POPIA and PAIA.

The applicable Information Officer details will be maintained and published as required.

Information Officer: Erik Coetzer
Email: legal@spinvisor.com

Where Deputy Information Officers are designated, their details will be maintained as required.

4. POPIA Processing Principles

SpinVisor seeks to process personal information in accordance with POPIA's conditions for lawful processing.

These include:

  • accountability;
  • processing limitation;
  • purpose specification;
  • further processing limitation;
  • information quality;
  • openness;
  • security safeguards; and
  • data-subject participation.

SpinVisor seeks to implement these principles throughout the lifecycle of personal information.

5. Categories of Personal Information

Depending on the user's interaction with SpinVisor, personal information may include:

Registration and account information

  • email address;
  • date of birth;
  • registration IP address;
  • internal account identifier;
  • SpinVisor handle;
  • account status;
  • subscription tier;
  • account timestamps;
  • authentication information; and
  • account-security information.

Optional profile information

Users may voluntarily provide:

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

These optional fields are not required for SpinVisor's core gameplay analytics.

Gameplay information

Gameplay information associated with an active SpinVisor account may include:

  • game title;
  • game provider;
  • casino/website;
  • gameplay events;
  • wager values;
  • spin results;
  • win/loss information;
  • displayed balance information;
  • tumble/cascade information;
  • multipliers;
  • bonus and feature information; and
  • related gameplay telemetry.

Session and analytical information

SpinVisor may generate:

  • session records;
  • session profit/loss;
  • observed RTP;
  • win rates;
  • average wager;
  • average win;
  • net result per spin;
  • tumble/cascade statistics;
  • feature statistics;
  • dry-spell statistics;
  • historical statistics;
  • variance-related metrics; and
  • other gameplay-derived metrics.

Technical and security information

This may include:

  • IP addresses;
  • browser information;
  • operating-system information;
  • extension version;
  • installation identifiers;
  • API request logs;
  • authentication/session information;
  • application/error logs;
  • security events; and
  • diagnostic information.

Support information

Information submitted through SpinVisor's support system may constitute personal information.

Users should avoid providing unnecessary sensitive information in support requests.

6. Purpose of Processing

SpinVisor may process personal information for purposes including:

  • registering users;
  • verifying age eligibility based on the date of birth supplied;
  • authenticating users;
  • operating the browser extension;
  • processing supported gameplay telemetry;
  • creating gameplay and session histories;
  • calculating gameplay statistics;
  • providing account functionality;
  • providing community functionality;
  • managing subscriptions;
  • communicating essential service information;
  • providing support;
  • securing accounts and infrastructure;
  • detecting fraud and abuse;
  • troubleshooting technical problems;
  • maintaining service reliability;
  • improving SpinVisor;
  • complying with applicable legal obligations; and
  • establishing, exercising or defending legal rights.

SpinVisor seeks not to collect personal information that is unnecessary for these purposes.

7. Gameplay Telemetry

SpinVisor processes supported gameplay telemetry in order to provide gameplay tracking, session history, metrics and analytical information.

While gameplay telemetry remains associated with a user's SpinVisor account or can reasonably be connected to that user through SpinVisor's systems, SpinVisor treats the relevant information as personal information where POPIA requires it.

SpinVisor distinguishes account-linked information from information that has been genuinely anonymised.

8. SpinVisor Handles

SpinVisor automatically assigns a pseudonymous handle when an account is created.

Users may change their handle subject to availability and SpinVisor's applicable rules.

Handles may be used in community functionality to avoid unnecessarily displaying a user's real-world identity.

A pseudonymous handle should not be treated as fully anonymous while SpinVisor can associate that handle with the underlying account.

9. 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.

Commercial telemetry datasets contain gameplay-event information rather than user-referenced information.

SpinVisor does not provide recipients of these commercial telemetry datasets with:

  • SpinVisor handles or nicknames;
  • anonymised or pseudonymised handles;
  • SpinVisor account/user 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.

User/account references are excluded from commercial telemetry datasets supplied to such recipients.

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

Where information supplied commercially could nevertheless reasonably identify a data subject, SpinVisor will treat that information according to applicable POPIA requirements rather than relying solely on its description as anonymous.

10. Information SpinVisor Does Not Request

SpinVisor is not designed to request or collect:

  • casino passwords;
  • casino login credentials;
  • online-banking credentials;
  • bank-account passwords;
  • complete payment-card numbers;
  • CVV/card security codes;
  • cryptocurrency private keys;
  • government identity documents;
  • passport information;
  • casino KYC documentation; or
  • private communications unrelated to SpinVisor's functionality.

Users should never provide such credentials to SpinVisor through profile fields, support tickets or other user-input areas.

11. Processing Limitation

SpinVisor seeks to process personal information lawfully and in a reasonable manner that does not unjustifiably infringe the privacy of users.

Where appropriate, SpinVisor limits processing to information that is adequate, relevant and reasonably necessary for its stated purposes.

SpinVisor's objective is not to monitor a user's general browsing activity.

Browser-extension access is intended to support SpinVisor functionality on supported websites and relevant technical contexts.

12. Purpose Specification

SpinVisor collects personal information for specific and defined purposes.

Where personal information is no longer reasonably required for those purposes, SpinVisor will delete, destroy or anonymise it subject to:

  • applicable legal requirements;
  • legitimate security requirements;
  • statutory retention obligations;
  • legal claims; and
  • the retention periods described in the Privacy Policy.

SpinVisor does not intend to retain identifiable personal information indefinitely merely because storage is technically possible.

13. Further Processing

Where SpinVisor processes personal information for a purpose beyond the purpose for which it was originally collected, SpinVisor will assess whether that further processing is compatible with the original purpose or otherwise permitted by POPIA.

Relevant factors may include:

  • the relationship between the original and subsequent purposes;
  • the nature of the information;
  • potential consequences for the data subject;
  • contractual relationships;
  • applicable legal requirements; and
  • safeguards applied to the information.

Commercial telemetry datasets supplied without user/account references are addressed separately in this Notice.

14. Information Quality

SpinVisor takes reasonably practicable steps to maintain appropriate accuracy and completeness of personal information having regard to the purpose for which it is processed.

Users may update certain information through their SpinVisor account.

Users may also request correction of inaccurate personal information through the privacy contact process.

Gameplay analytics may depend upon information observed from casino websites and game providers.

Where SpinVisor-displayed gameplay information conflicts with authoritative information supplied directly by the applicable casino operator or game provider, the applicable casino or game-provider records and values remain the source of truth.

15. Openness and Transparency

SpinVisor seeks to provide users with clear information concerning its processing activities through:

  • the SpinVisor Privacy Policy;
  • this POPIA Compliance Notice;
  • the Extension Data Collection Statement;
  • account interfaces;
  • browser permission interfaces; and
  • additional notices where appropriate.

SpinVisor's intention is that users should be able to understand what information is processed and why.

16. Browser Extension Permissions

SpinVisor requires access to supported websites in order to detect and process supported gameplay telemetry.

Where browser-level permission is required, users control whether that permission is granted.

SpinVisor does not override a user's browser-level decision to deny access.

If permission is denied or removed, functionality requiring that access will not operate.

Further information is contained in the SpinVisor Extension Data Collection Statement.

17. Information Security

SpinVisor uses reasonable technical and organisational measures intended to protect personal information against:

  • loss;
  • damage;
  • unauthorised destruction;
  • unlawful access;
  • unauthorised processing;
  • unauthorised alteration; and
  • unauthorised disclosure.

Measures may include:

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

Security safeguards are reviewed and adapted where reasonably appropriate.

18. Operators and Service Providers

SpinVisor uses third parties to assist with infrastructure and operational functions.

Depending on the service, these may include:

  • Vander Host;
  • Amazon Web Services (AWS);
  • Cloudflare;
  • payment/subscription service providers;
  • tax-management providers; and
  • other service providers required to operate SpinVisor.

Where a third party processes personal information for SpinVisor as an operator, SpinVisor seeks to maintain appropriate contractual and security arrangements as required by applicable law.

SpinVisor's current infrastructure arrangements are described more fully in the Privacy Policy.

19. Security Compromises

SpinVisor maintains processes intended to identify, investigate, contain and respond to security compromises involving personal information.

Where there are reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, SpinVisor will address notification obligations under POPIA.

Where legally required, SpinVisor will notify:

  • the Information Regulator; and
  • affected data subjects

in accordance with applicable requirements.

An operator processing information on SpinVisor's behalf is expected to notify SpinVisor where the operator becomes aware of a relevant security compromise so that SpinVisor can assess and fulfil its obligations as responsible party.

20. Cross-Border Processing

SpinVisor provides services to a global user base and uses infrastructure that may involve processing or access outside South Africa.

SpinVisor does not guarantee that all personal information will remain exclusively within the user's country.

Where personal information is transferred from South Africa to a recipient in another country, SpinVisor will address the requirements of section 72 of POPIA.

Depending on the circumstances, an international transfer may be permitted where:

  • the recipient is subject to a law, binding corporate rules or binding agreement providing an adequate level of protection;
  • the data subject consents to the transfer;
  • the transfer is necessary for performance of a contract involving the data subject;
  • the transfer is necessary for implementation or conclusion of a contract in the data subject's interest; or
  • another applicable POPIA condition permits the transfer.

Authorised SpinVisor personnel in South Africa may remotely access systems where necessary for administration, security, support and operations.

21. Data Subject Rights

Subject to POPIA and other applicable law, data subjects may have rights concerning their personal information.

These may include rights to:

  • request confirmation that SpinVisor holds personal information about them;
  • request access to qualifying personal information;
  • request correction of inaccurate information;
  • request deletion or destruction where legally applicable;
  • object to certain processing;
  • withdraw consent where processing is based on consent;
  • object to certain direct marketing;
  • lodge a complaint with the Information Regulator; and
  • exercise other rights provided by POPIA.

These rights may be subject to lawful limitations.

22. Access to Personal Information

A data subject may request confirmation of whether SpinVisor holds personal information concerning them.

Where applicable, a data subject may request access to their personal information according to the procedures required by POPIA and PAIA.

SpinVisor may request reasonable information necessary to verify the identity or authority of the person making the request.

SpinVisor will not intentionally disclose personal information to a person who is not entitled to receive it.

23. Correction and Deletion

Users may request correction or deletion of personal information where permitted by POPIA.

SpinVisor may also provide account functionality through which certain information can be updated directly.

Account deletion is addressed in the Privacy Policy.

Following account deletion:

  • account access terminates;
  • account-linked personal information is removed from active production systems;
  • the user loses access to historical gameplay records; and
  • retained historical gameplay information is anonymised.

Once properly anonymised, historical gameplay information cannot be reconnected to the former account.

24. Objection to Processing

Where POPIA provides a right to object to processing, a data subject may submit an objection through SpinVisor's applicable privacy process.

SpinVisor will consider the objection according to POPIA and the circumstances of the processing.

An objection does not necessarily require SpinVisor to stop processing where applicable law permits or requires the processing to continue.

25. Direct Marketing

SpinVisor's newsletter is operated separately from essential service communications.

Users may unsubscribe from newsletter communications through the unsubscribe functionality provided.

After unsubscribe, SpinVisor may retain a minimal suppression record where reasonably necessary to ensure that the unsubscribe instruction continues to be honoured.

The SpinVisor website uses Google Analytics to measure website usage. SpinVisor does not currently use Meta Pixel or comparable advertising pixels for direct marketing.

Essential account, security, subscription, inactivity and policy communications are not treated as optional marketing communications merely because they are delivered electronically.

26. Automated Processing

SpinVisor automatically processes gameplay telemetry to calculate gameplay metrics and statistics.

Examples may include:

  • observed RTP;
  • session profit/loss;
  • win rate;
  • average wager;
  • average win;
  • net result per spin;
  • feature statistics;
  • variance-related metrics; and
  • historical gameplay measurements.

These calculations describe gameplay activity.

SpinVisor does not make gambling decisions on behalf of users.

Users decide for themselves whether to gamble, continue or stop gambling, select a game, place a wager, purchase a game feature or otherwise participate in gambling.

Where SpinVisor introduces automated processing that triggers additional requirements under POPIA concerning automated decision-making, SpinVisor will implement the safeguards required by applicable law.

27. Account Inactivity

SpinVisor applies an inactivity process to registered accounts.

If no qualifying activity is detected for 30 consecutive days, SpinVisor may notify the user that the account is inactive and scheduled for deletion on Day 60 if activity does not resume.

If inactivity continues, a further notification may be sent at approximately Day 45.

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

If the account remains inactive 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 that the account has been deleted.

A new registration is required to use SpinVisor again.

Previously anonymised gameplay history cannot be recovered or reconnected.

28. Retention

SpinVisor applies retention periods according to the category and purpose of information.

These are described more fully in the Privacy Policy and generally include:

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

Retention periods may be adjusted where required by law, security requirements or legal proceedings.

29. Backups

Personal 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 after deletion from active production systems.

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

30. Anonymisation

SpinVisor may retain historical gameplay information after account deletion only after applying its anonymisation process.

The process is intended to sever information capable of reconnecting retained historical gameplay data to the former account.

This includes removing or severing, where applicable:

  • account IDs;
  • email addresses;
  • IP addresses;
  • authentication identifiers;
  • original SpinVisor handles;
  • optional names;
  • profile information;
  • profile-image references;
  • support references; and
  • other account-linking information.

A generic statistical identifier may replace the former account reference where required for dataset integrity.

That identifier is not intended to permit the former user to be identified or reconnected.

Genuinely anonymised statistical information may be retained indefinitely.

31. Children

SpinVisor is restricted to persons aged 18 years or older.

Date of birth is required during registration for age screening.

Where the supplied date of birth indicates that the person is under 18, access will not be granted.

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

Users are required to provide truthful registration information.

Failed under-age registration attempts may be recorded in security logs and retained according to SpinVisor's applicable security-retention period.

32. Exercising POPIA Rights

Privacy requests may be directed to:

Information Officer: Erik Coetzer
Privacy/Information Officer Email: legal@spinvisor.com

The request should contain sufficient information for SpinVisor to:

  • understand the request;
  • identify the relevant account or information; and
  • reasonably verify that the requester is the data subject or an authorised person.

SpinVisor may request additional information where reasonably necessary to prevent unauthorised disclosure or deletion.

33. Information Regulator

Data subjects may have the right to lodge a complaint with the Information Regulator (South Africa) concerning the processing of personal information.

Information concerning complaints and POPIA rights is available from the Information Regulator.

SpinVisor encourages users to contact its Information Officer where appropriate so that the issue can first be investigated, but this does not remove a data subject's right to approach the Information Regulator.

34. Promotion of Access to Information Act

Dynemetry (Pty) Ltd is also subject to applicable requirements of the Promotion of Access to Information Act 2 of 2000 (“PAIA”).

Where required, Dynemetry will maintain a PAIA Manual describing matters including:

  • company and Information Officer details;
  • categories of records;
  • records available in terms of applicable legislation;
  • procedures for requesting access;
  • applicable request forms;
  • applicable fees;
  • grounds upon which access may lawfully be refused;
  • categories of data subjects and personal information processed; and
  • other information required by PAIA.

A PAIA request is different from an ordinary customer-support request.

Where a formal PAIA request is required, the requester must follow the applicable PAIA process.

35. PAIA Manual

SpinVisor's website will provide access to Dynemetry (Pty) Ltd's applicable PAIA Manual where publication is required.

PAIA Manual: PAIA Manual

The PAIA Manual should be read together with:

  • this POPIA Compliance Notice;
  • the SpinVisor Privacy Policy; and
  • the applicable guidance and forms published by the Information Regulator.

36. Information Officer Registration

Dynemetry (Pty) Ltd will maintain the registration of its applicable Information Officer and any Deputy Information Officers with the Information Regulator as required.

SpinVisor will not publish a statement claiming that registration has been completed until the applicable registration has in fact been completed.

37. Personal Information Impact Assessments

SpinVisor may conduct Personal Information Impact Assessments or other privacy-risk assessments where appropriate to identify and manage risks associated with personal-information processing.

Such assessments may be particularly appropriate where SpinVisor:

  • introduces significant new processing;
  • materially changes its telemetry architecture;
  • introduces new categories of personal information;
  • materially changes community functionality;
  • introduces new commercial data-processing arrangements; or
  • otherwise introduces processing that may create increased privacy risks.

Where POPIA or regulatory requirements mandate an assessment or prior authorisation, SpinVisor will address the applicable requirement before undertaking the relevant processing.

38. Changes to This Notice

SpinVisor may update this POPIA Compliance Notice where:

  • processing practices change;
  • infrastructure changes;
  • POPIA requirements change;
  • regulatory guidance changes;
  • SpinVisor introduces new functionality; or
  • other changes make an update necessary.

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

Material changes will be communicated where required by applicable law.

39. Related 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;
  • CCPA/CPRA Privacy Notice;
  • Cookie Policy;
  • Responsible Gambling / Responsible Play Policy;
  • Subscription, Cancellation & Refund Policy; and
  • Gambling & Analytics Disclaimer.

40. Contact

POPIA and privacy enquiries may be directed to:

SpinVisor
A division of Dynemetry (Pty) Ltd
South Africa

Website: www.spinvisor.com
Information Officer: Erik Coetzer
Privacy/Information Officer Email: legal@spinvisor.com
Registered/Business Address: 10 Payne St, Penzance Estate, Cape Town, Western Cape, 7806

Formal PAIA access requests should be submitted according to the procedure contained in Dynemetry (Pty) Ltd's PAIA Manual.

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